# Do UK firms have to label AI in their adverts?

The UK and the EU answer this differently, so where people see your advert changes what you must do.

The Assurance Desk. Published 27 October 2026. Last checked 27 October 2026.

**The short answer.** Not under UK law. There is no blanket legal requirement in the UK to disclose AI in ads, but the usual rules still apply. In the EU, the AI Act has required clear labels on deepfakes since 2 August 2026 ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), [European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act) and [European Commission, Quick Facts: Transparency rules for AI systems](https://digital-strategy.ec.europa.eu/en/factpages/quick-facts-transparency-rules-ai-systems), checked 27 October 2026).

## Is there a UK law that says you must label AI in adverts?

No UK law makes you label AI in adverts. In the regulator's words, there is no blanket legal requirement in the UK to disclose the use of AI in ads ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), checked 27 October 2026).

The usual rules still apply. The UK's CAP and BCAP Codes have no AI-specific rules, but the existing rules apply however content is generated, edited or targeted ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), checked 27 October 2026).

There is no separate section of the CAP Code for AI-generated ads. Ads that use deepfakes must meet the rules on misleading advertising, especially on testimonials and endorsements ([asa.org.uk, In at the Deep(fake) End, ASA, CAP](https://www.asa.org.uk/news/in-at-the-deep-fake-end.html), checked 27 October 2026).

A celebrity who appears to endorse a product they have no link with can create problems, including with the CAP Code ([asa.org.uk, In at the Deep(fake) End, ASA, CAP](https://www.asa.org.uk/news/in-at-the-deep-fake-end.html), checked 27 October 2026).

The ASA and CAP published this advice on 29 May 2025. They expect EU and global AI laws to affect the UK too, particularly for brands that advertise globally ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), checked 27 October 2026).

## When should a UK advert say it used AI?

For a UK advert, the test is whether people would be misled. The ASA and CAP suggest asking first whether the audience is likely to be misled if the use of AI is not disclosed ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), checked 27 October 2026).

If there is a danger of misleading, the next question is whether the disclosure clarifies the advert's message or contradicts it ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), checked 27 October 2026).

A label does not fix a misleading advert. A disclosure alone is very unlikely to mitigate the harm of a fundamentally misleading message ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), checked 27 October 2026).

An AI image that shows a cosmetic product's effect inaccurately is likely to be materially misleading, even with an AI disclosure ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), checked 27 October 2026).

A disclosure can help in other cases. Saying that a deepfake is only for comedic effect, or that an influencer is AI-generated, could help to negate a misleading impression ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), checked 27 October 2026).

Industry bodies go a little further. In 2023, ISBA and the IPA produced twelve guiding principles on the use of generative AI in advertising ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), checked 27 October 2026).

One principle asks for transparency where AI features prominently in an ad and is unlikely to be obvious to consumers ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), checked 27 October 2026).

The ASA and CAP see issues with requiring every ad made with AI to be labelled. They say they are ready to change their approach as the technology moves ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), checked 27 October 2026).

**Should a UK advert say it used AI?**

- Would people be misled if you did not say AI was used?: If not, UK rules need no disclosure, but the advert must still not mislead. (yes → Would a disclosure clarify the message, not contradict it?)
- Would a disclosure clarify the message, not contradict it?: If it would contradict the message, a label will not fix it. Change the advert. (yes → Say that AI was used)
- Say that AI was used: Make the disclosure clear, in a way that clarifies the message.

The ASA and CAP's two questions, in order. A label never fixes a misleading claim.

Source: asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP, https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html (checked 27 October 2026)

## Does the EU AI Act apply to a UK firm's adverts?

The EU AI Act can apply to a UK firm's adverts. It covers providers and deployers of AI systems outside the EU, where the output of the AI system is used in the EU ([EUR-Lex, Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024](https://eur-lex.europa.eu/eli/reg/2024/1689/oj/eng), checked 27 October 2026).

The deployer is the business that uses the AI system. Where an advertising company uses one, its staff, such as digital animators and content creators, are not separate deployers ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), checked 27 October 2026).

Article 50 of the AI Act applies from 2 August 2026, and from then providers and deployers must comply ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), checked 27 October 2026).

Deployers must disclose deepfakes, and mark text on matters of public interest, with clear and perceivable labels ([European Commission, Quick Facts: Transparency rules for AI systems](https://digital-strategy.ec.europa.eu/en/factpages/quick-facts-transparency-rules-ai-systems), checked 27 October 2026).

Providers, the firms that make the AI tools, must apply a machine-readable mark to AI-generated content, unless the system only assists standard editing ([European Commission, Quick Facts: Transparency rules for AI systems](https://digital-strategy.ec.europa.eu/en/factpages/quick-facts-transparency-rules-ai-systems), checked 27 October 2026).

**Labelling AI in adverts: the UK and the EU**

- **UK**
  - No blanket legal requirement to disclose AI in ads
  - The CAP and BCAP rules apply however an ad is made
  - Disclose when leaving it out would mislead
- **EU**
  - Article 50 of the AI Act applies from 2 August 2026
  - Deployers label deepfakes with clear and perceivable labels
  - Text on matters of public interest needs a label unless a person reviewed it

Where people see the advert decides which rules apply. A UK firm can be covered by both.

Source: asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP, https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html (checked 27 October 2026); European Commission, Transparency obligations under Article 50 of the AI Act, https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act (checked 27 October 2026); European Commission, Quick Facts: Transparency rules for AI systems, https://digital-strategy.ec.europa.eu/en/factpages/quick-facts-transparency-rules-ai-systems (checked 27 October 2026); EUR-Lex, Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024, https://eur-lex.europa.eu/eli/reg/2024/1689/oj/eng (checked 27 October 2026)

## What counts as a deepfake in an advert?

Under the EU AI Act, a deepfake is AI-made or AI-changed image, audio or video. It resembles existing persons, objects, places, entities or events, and would falsely appear authentic or truthful ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), checked 27 October 2026).

Article 50(4) says the deployer shall disclose that such content has been artificially generated or manipulated ([EUR-Lex, Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024](https://eur-lex.europa.eu/eli/reg/2024/1689/oj/eng), checked 27 October 2026).

Not every AI edit counts. AI-made background scenes, special effects or technical processing in standard film production are not likely to make content falsely appear authentic ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), checked 27 October 2026).

When a label is needed, people must see it by the time they first see the content. It must be clear and distinguishable ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), checked 27 October 2026).

The hidden machine-readable mark from the AI tool is not enough. Deployers cannot rely on it to meet their disclosure duty ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), checked 27 October 2026).

Evidently artistic, creative, satirical or fictional works still need a disclosure. It must not hamper the display or enjoyment of the work ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), checked 27 October 2026).

## Does AI-written advert copy need a label?

AI-written advert copy needs an EU label only when it informs the public on matters of public interest and no person reviewed it ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act) and [European Commission, Quick Facts: Transparency rules for AI systems](https://digital-strategy.ec.europa.eu/en/factpages/quick-facts-transparency-rules-ai-systems), checked 27 October 2026).

Matters of public interest include public health, environmental protection, consumer safety and economic or financial developments, among others ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), checked 27 October 2026).

Published text that has undergone human review or editorial control does not need to be labelled ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), checked 27 October 2026).

A quick check is not enough. Spell-checking or grammar correction does not count as human review or editorial control ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), checked 27 October 2026).

## What are the key dates for the EU labelling rules?

The key date for the EU labelling rules is 2 August 2026, when Article 50 started to apply ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), checked 27 October 2026).

Deepfakes generated before 2 August 2026 do not have to be labelled retroactively, but labelling them is encouraged ([European Commission, Quick Facts: Transparency rules for AI systems](https://digital-strategy.ec.europa.eu/en/factpages/quick-facts-transparency-rules-ai-systems), checked 27 October 2026).

Tool makers have a grace period for the marking duty until December 2026. It covers generative AI systems placed on the market before 2 August 2026 ([European Commission, Quick Facts: Transparency rules for AI systems](https://digital-strategy.ec.europa.eu/en/factpages/quick-facts-transparency-rules-ai-systems), checked 27 October 2026).

The European Commission's guidelines on these duties are dated 20 July 2026. They give definitions, exemptions and practical examples of what is in and out of scope ([European Commission, Commission publishes guidelines on transparency obligations for providers and deployers of certain AI systems](https://digital-strategy.ec.europa.eu/en/news/commission-publishes-guidelines-transparency-obligations-providers-and-deployers-certain-ai-systems) and [European Commission, Guidelines on transparency obligations for providers and deployers of certain AI systems](https://digital-strategy.ec.europa.eu/en/policies/guidelines-ai-transparency-obligations), checked 27 October 2026).

The Commission's Code of Practice on AI-generated content is voluntary, but the Article 50 requirements are legal obligations ([European Commission, Code of Practice on Transparency of AI-generated Content](https://digital-strategy.ec.europa.eu/en/policies/code-practice-ai-generated-content), checked 27 October 2026).

The Commission and the AI Board have confirmed that the code is an adequate tool to show compliance. It has a section for deployers on labelling deepfakes and AI-generated text ([European Commission, Code of Practice on Transparency of AI-generated Content](https://digital-strategy.ec.europa.eu/en/policies/code-practice-ai-generated-content), checked 27 October 2026).

By the end of July 2026, about 190 companies and organisations had signed it. Firms that do not sign must show compliance through other equally adequate means ([European Commission, Guidelines on transparency obligations for providers and deployers of certain AI systems](https://digital-strategy.ec.europa.eu/en/policies/guidelines-ai-transparency-obligations) and [European Commission, Code of Practice on Transparency of AI-generated Content](https://digital-strategy.ec.europa.eu/en/policies/code-practice-ai-generated-content), checked 27 October 2026).

The EU also created 3 optional icons to label AI-generated content ([European Commission, Quick Facts: Transparency rules for AI systems](https://digital-strategy.ec.europa.eu/en/factpages/quick-facts-transparency-rules-ai-systems), checked 27 October 2026).

Fines can reach 15 million euros or 3% of total worldwide turnover, and proportionality can be taken into account for SMEs ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), checked 27 October 2026).

**Labelling AI in adverts: the key dates**

- 29 May 2025, UK: The ASA and CAP publish advice on disclosing AI in adverts.
- 20 July 2026, EU: The European Commission's guidelines on the transparency duties.
- 2 August 2026, EU: Article 50 of the AI Act applies.
- December 2026, EU: The grace period for marking ends, for AI systems already on the market.

The UK date is advice from the regulator. The EU dates come from the AI Act and the European Commission.

Source: asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP, https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html (checked 27 October 2026); European Commission, Commission publishes guidelines on transparency obligations for providers and deployers of certain AI systems, https://digital-strategy.ec.europa.eu/en/news/commission-publishes-guidelines-transparency-obligations-providers-and-deployers-certain-ai-systems (checked 27 October 2026); European Commission, Transparency obligations under Article 50 of the AI Act, https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act (checked 27 October 2026); European Commission, Quick Facts: Transparency rules for AI systems, https://digital-strategy.ec.europa.eu/en/factpages/quick-facts-transparency-rules-ai-systems (checked 27 October 2026)

## What to do

1. Check where people will see the advert, because the EU AI Act covers output used in the EU ([EUR-Lex, Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024](https://eur-lex.europa.eu/eli/reg/2024/1689/oj/eng), checked 27 October 2026).
2. For a UK advert, ask whether people would be misled if you did not say AI was used ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), checked 27 October 2026).
3. Do not rely on a label to fix a misleading claim ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), checked 27 October 2026).
4. For an advert seen in the EU, label any deepfake clearly, at the latest when people first see it ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), checked 27 October 2026).
5. Have a person review AI-written text on matters of public interest, or label it ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act) and [European Commission, Quick Facts: Transparency rules for AI systems](https://digital-strategy.ec.europa.eu/en/factpages/quick-facts-transparency-rules-ai-systems), checked 27 October 2026).

## Common questions

### Does Article 50 apply to my business, and what disclosure text do I need?

It can, if you use AI to make content that people in the EU see. You must disclose that the content was artificially generated or manipulated, in a clear and distinguishable way. The EU created 3 optional icons for this ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), [European Commission, Quick Facts: Transparency rules for AI systems](https://digital-strategy.ec.europa.eu/en/factpages/quick-facts-transparency-rules-ai-systems) and [EUR-Lex, Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024](https://eur-lex.europa.eu/eli/reg/2024/1689/oj/eng), checked 27 October 2026).

### Do we have to label adverts made before 2 August 2026?

No. Deepfakes generated before 2 August 2026 do not have to be labelled retroactively, but labelling them is encouraged ([European Commission, Quick Facts: Transparency rules for AI systems](https://digital-strategy.ec.europa.eu/en/factpages/quick-facts-transparency-rules-ai-systems), checked 27 October 2026).

### Does a label make a misleading UK advert acceptable?

No. A disclosure alone is very unlikely to mitigate the harm of a fundamentally misleading message ([asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP](https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html), checked 27 October 2026).

### Does the mark from our AI tool count as the label?

No. Deployers cannot rely on the machine-readable mark from the provider to meet their disclosure duty ([European Commission, Transparency obligations under Article 50 of the AI Act](https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act), checked 27 October 2026).

## Where next

- [Exposed to the EU AI Act](https://theassurancedesk.com/best/eu-ai-act-exposed.md)
- [What does the EU AI Act ask of a UK business?](https://theassurancedesk.com/guides/eu-ai-act-uk-business.md)
- [EU AI Act timeline: the key dates after the July 2026 changes](https://theassurancedesk.com/guides/eu-ai-act-timeline.md)
- [How does the UK regulate AI?](https://theassurancedesk.com/guides/uk-ai-regulation.md)
- [Who can help a UK firm with the EU AI Act?](https://theassurancedesk.com/guides/who-can-help-uk-firm-eu-ai-act.md)

## Sources

- asa.org.uk, Disclosure of AI in Advertising: Striking the Balance Between Creativity and Responsibility, ASA, CAP: https://www.asa.org.uk/news/disclosure-of-ai-in-advertising-striking-the-balance-between-creativity-and-responsibility.html (checked 27 October 2026)
- European Commission, Transparency obligations under Article 50 of the AI Act: https://digital-strategy.ec.europa.eu/en/faqs/transparency-obligations-under-article-50-ai-act (checked 27 October 2026)
- European Commission, Quick Facts: Transparency rules for AI systems: https://digital-strategy.ec.europa.eu/en/factpages/quick-facts-transparency-rules-ai-systems (checked 27 October 2026)
- asa.org.uk, In at the Deep(fake) End, ASA, CAP: https://www.asa.org.uk/news/in-at-the-deep-fake-end.html (checked 27 October 2026)
- EUR-Lex, Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024: https://eur-lex.europa.eu/eli/reg/2024/1689/oj/eng (checked 27 October 2026)
- European Commission, Commission publishes guidelines on transparency obligations for providers and deployers of certain AI systems: https://digital-strategy.ec.europa.eu/en/news/commission-publishes-guidelines-transparency-obligations-providers-and-deployers-certain-ai-systems (checked 27 October 2026)
- European Commission, Guidelines on transparency obligations for providers and deployers of certain AI systems: https://digital-strategy.ec.europa.eu/en/policies/guidelines-ai-transparency-obligations (checked 27 October 2026)
- European Commission, Code of Practice on Transparency of AI-generated Content: https://digital-strategy.ec.europa.eu/en/policies/code-practice-ai-generated-content (checked 27 October 2026)

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**Who publishes this.** The Assurance Desk is published by Add-Venture Advisory Ltd, company number 11854524, registered in England and Wales. The same owner runs Avouch, a marketing agency that sells AI visibility services to firms of the kind this site covers. That is a conflict of interest, and it is disclosed here.