AI disclosure scenario
Do you need to disclose a synthetic customer review?
Direct answer
Yes, a realistic synthetic customer review normally needs AI disclosure, but disclosure is not the whole analysis. If the performer claims or implies real product experience that never occurred, the asset can create a separate testimonial or deception risk. Pause publication, verify the experience claim and route the script and evidence to accountable human or legal review.
Applies when
- Article 50 and platform rules decide whether the artificial image, audio or video needs an AI disclosure. That label describes how the media was made; it does not establish that a represented product experience is real.
- EU unfair-commercial-practices rules separately address false consumer reviews or endorsements and misleading presentation. The Commission's guidance says the classification depends on how the average consumer perceives the material, not only on whether the publisher literally calls it a review.
Doesn't apply when
- A real, verified customer gives their own authorized testimonial and AI is used only for non-material caption formatting; advertising and endorsement requirements still remain.
- An obviously fictional character performs a clearly framed brand skit without claiming personal product experience, although a broader platform AI label may still apply.
- An unpublished internal concept is used only for review and never shown to an external audience.
Worked decision
Example
A photorealistic AI performer records a selfie-style Reel saying, ‘I used this serum for two weeks and my skin changed.’
Decision: Human review required
The asset combines a synthetic performer, review-style presentation and a claim of real product experience. An AI label identifies synthetic production but may not resolve the fabricated-experience impression.
AI-generated dramatization. No real customer testimonial or product experience is depicted.
Next steps
Required action
- Record the generated or altered component, source asset, tool and destination before publishing.
- Apply the native platform label wherever the applicable platform workflow requires it.
- Use component-specific wording such as: “AI-generated dramatization. No real customer testimonial or product experience is depicted.”
Publishing layer
Platform differences
TikTok
Apply the AIGC label to realistic generated image, audio or video. Then assess the scripted experience and endorsement separately; the native AI label does not substantiate a customer claim.
Open platform guide →Instagram and Facebook
Meta may show AI info from technical signals or publisher disclosure. Do not treat that label as permission to make a synthetic performer look like an independent customer.
Open platform guide →YouTube
Use the altered-content disclosure for realistic synthetic media where required, and independently review testimonial, endorsement and product-experience claims before upload.
Open platform guide →Evidence
Source
Freshness and accountability
Last verified
Last reviewed 2026-09-14 · Current
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Copy-ready language
Disclosure wording options
AI-generated dramatization. No real customer testimonial or product experience is depicted.
AI-generated presenter reading a brand script; not an independent customer review.
Related guides
“Doesn't apply” means no disclosure requirement is identified for the facts stated here. A client policy, advertising rule or another destination platform can still be stricter. This page is source-backed information, not legal advice.