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United Kingdom: Transparency & Synthetic Content

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CAP and ASA guidance on AI-generated advertising and deepfakes (Published 2026-06-11): Self-regulatory guidance from CAP and the ASA saying the CAP and BCAP Codes contain no AI-specific rules but apply media-neutrally: misleading deepfake endorsements, harmful AI-generated images and automated ad campaigns are judged under the existing Codes and the advertiser stays responsible.

5 instruments · 6 obligations · 16 claims · Next: (Ofcom evidence request on protections for women and girls closes)

5 instruments (5 current) · 6 obligations · 16 claims · 6 milestones

Instruments

  • CAP and ASA guidance on AI-generated advertising and deepfakes Published 2026-06-11

    Self-regulatory guidance from CAP and the ASA saying the CAP and BCAP Codes contain no AI-specific rules but apply media-neutrally: misleading deepfake endorsements, harmful AI-generated images and automated ad campaigns are judged under the existing Codes and the advertiser stays responsible.

    Regulatory expectation · Authority: Advertising Standards Authority and Committee of Advertising Practice · Verified · Official text
  • CMA guidance: Complying with consumer law when using AI agents Published 2026-03-09

    CMA guidance of 9 March 2026 telling businesses that they are responsible for what an AI agent does as for an employee, that they should consider labelling AI agents, and that they should train, monitor and quickly refine agents, with a human in the loop. It sits alongside CMA research on agentic AI and consumers.

    Non-binding · Authority: Competition and Markets Authority · Verified · Official text
  • CMA publisher conduct requirement on Google general search (generative AI controls) Published 2026-06-03; entry into force not recorded

    Conduct requirement imposed by the CMA on Google requiring publisher controls over use of search content in generative AI, clear information, engagement metrics and attribution.

    Binding · Authority: Competition and Markets Authority · Verified · Official text
  • Data (Use and Access) Act 2025 In force since 2025-08-20

    Act amending UK data protection law; for AI governance it creates the s.138 purported-intimate-image offences, the ss.135-137 copyright-and-AI reporting duties, and establishes the Information Commission.

    Binding · Authority: Information Commission (successor to the Information Commissioner's Office) · Verified · Official text
  • Online Safety Act 2023 Date not recorded

    Act imposing illegal-content risk assessment and safety duties on regulated user-to-user and search services, enforced by Ofcom with penalties of up to the greater of £18 million or 10% of qualifying worldwide revenue. Ofcom has said it applies to generative AI chatbots and platforms.

    Binding · Authority: Office of Communications (Ofcom) · Verified · Official text

Obligations

  • Sexual Offences Act 2003 s.66E (inserted by DUAA s.138)

    It is an offence to intentionally create a purported intimate image of another person without consent and without reasonable belief in consent.

    prohibition · Applies to: other · Data (Use and Access) Act 2025
  • Online Safety Act 2023 s.9(2)

    Providers of regulated user-to-user services must carry out a suitable and sufficient illegal content risk assessment.

    risk management · Applies to: provider · Online Safety Act 2023
  • Publisher conduct requirement (final decision and notice)

    Google must provide publishers with effective controls over use of their search content in generative AI and related transparency, metrics and attribution measures.

    transparency disclosure · Applies to: provider · CMA publisher conduct requirement on Google general search (generative AI controls)
  • Guidance section "Tell your customers if you use an AI agent"

    Businesses using AI agents with customers should consider labelling them so customers are not misled into thinking a real person provides the service, and should not overstate the role of AI.

    transparency disclosure · Applies to: deployer · CMA guidance: Complying with consumer law when using AI agents
  • CAP Code (media-neutral application to AI-generated ads); CAP News 11 June 2026

    Advertisers using AI to create or distribute ads, including deepfakes and automated ad platforms, must make the ads comply with the CAP Code and remain responsible for AI output used in their ads.

    other · Applies to: deployer · CAP and ASA guidance on AI-generated advertising and deepfakes
  • Automated Vehicles Act 2024 s.79 (Part 4)

    It is an offence to make, in the course of business, a communication about a product or service likely to confuse end-users in Great Britain as to whether a vehicle that is not an authorised automated vehicle can travel autonomously, safely and legally; due-diligence defences apply.

    transparency disclosure · Applies to: provider · Automated Vehicles Act 2024

Milestones

  • Sexual Offences Act 2003 ss.66E-66F (purported intimate image offences) in force Met
    Data (Use and Access) Act 2025
  • CMA guidance on complying with consumer law when using AI agents published Met
    CMA guidance: Complying with consumer law when using AI agents
  • Section 136 report on copyright works and AI due within nine months of 19 June 2025; report published 18 March 2026 Met
    Data (Use and Access) Act 2025
  • CAP guidance "AI and Deepfakes: Four Things Advertisers Need to Know" published Met
    CAP and ASA guidance on AI-generated advertising and deepfakes
  • Ofcom expectation that platforms have hash-matching for illegal intimate images and deepfakes in place Status not recorded
    Online Safety Act 2023
  • Ofcom evidence request on protections for women and girls closes Upcoming
    Online Safety Act 2023
Claims and evidence (16)

  • Derived: Probable Section 138 of the Data (Use and Access) Act 2025, creating offences of intentionally creating or requesting the creation of a purported intimate image of another person without consent, came into force on 6 February 2026 under SI 2026/31.

    Confidence: Confirmed · As of 6 Feb 2026 · evidenced
    Evidence and sources

  • Derived: Probable Section 99 of the Crime and Policing Act 2026 inserts Sexual Offences Act 2003 section 66I, making it an offence to make, adapt, supply or offer to supply a 'nudification' tool for generating purported intimate images; section 99 came into force on 29 June 2026.

    Confidence: Confirmed · As of 29 Jun 2026 · evidenced
    Evidence and sources

  • CAP confirmed on 11 June 2026 that the media-neutral CAP Code applies to AI-generated advertising content, including deepfakes, and the ASA has upheld rulings against harmful AI-generated images on that basis.

    Confidence: Probable · As of 11 Jun 2026 · evidenced
    Evidence and sources

  • Derived: Probable Ofcom published an open letter reminding providers what the Online Safety Act regulates and how it applies to generative AI chatbot tools and platforms.

    Confidence: Probable · evidenced
    Evidence and sources

  • Section 9 of the Online Safety Act 2023 requires providers of regulated user-to-user services to carry out a suitable and sufficient illegal content risk assessment.

    Confidence: Probable · evidenced
    Evidence and sources

  • The publisher conduct requirement requires Google to provide publishers with effective controls over the use of their search content in generative AI, among other transparency and attribution obligations.

    Confidence: Probable · As of 3 Jun 2026 · evidenced
    Evidence and sources

  • The ASA/CAP state that the media-neutral CAP Code applies in full to AI-generated advertising, and recent rulings have found harmful AI-generated images in breach of the Code on the same basis as any other image.

    Confidence: Probable · As of 11 Jun 2026 · evidenced
    Evidence and sources

  • The guidance says businesses should consider labelling AI agents so they do not mislead customers into thinking they deal with a real person, and should keep a human in the loop checking the agent's decisions.

    Confidence: Probable · As of 9 Mar 2026 · evidenced
    Evidence and sources
    • Complying with consumer law when using AI agents (CMA guidance) T1 · retrieved · retrieved 8 Oct 2026 · Section "Tell your customers if you use an AI agent"If you use an AI agent, consider whether you need to label it so you do not mislead customers into thinking that a service is being provided by a real person – if the fact they are dealing with AI rather than a person might affect people's decisions then you should tell them. Do not overstate the ro
    • Complying with consumer law when using AI agents (CMA guidance) T1 · retrieved · retrieved 8 Oct 2026 · Section "Monitor how your AI agents are performing"Make sure there is a human in the loop, actively checking that the AI agent is making correct decisions and generating expected results. Regular human oversight is important to catch mistakes and ensure that AI agents are completing tasks in a legally complian

  • The guidance applies the DMCCA to AI agents running marketing campaigns, processing refunds, answering customer queries and providing comparison services, including accurate pricing, labelled paid endorsements and genuine offers.

    Confidence: Probable · As of 9 Mar 2026 · evidenced
    Evidence and sources
    • Complying with consumer law when using AI agents (CMA guidance) T1 · retrieved · retrieved 8 Oct 2026 · Example: using an AI agent to run your latest marketing campaignThink about the requirements of the Digital Markets, Competition and Consumers Act 2024 when you design and train the AI. For example:
    • Complying with consumer law when using AI agents (CMA guidance) T1 · retrieved · retrieved 8 Oct 2026 · Section "When it comes to dealing with your customers, the same rules apply whether using AI or human agents"It's important to remember that you are responsible for what an AI agent does in the same way you are responsible for what an employee does. This is true even if someone else designed or provides the AI agent on your behalf - so make sure you think about compliance with consumer law if you are procu

  • CAP published "AI and Deepfakes: Four Things Advertisers Need to Know Before They Hit Run" on 11 June 2026, following earlier AI and deepfake guidance of 8 February 2024, 7 February 2025 and 12 June 2025.

    Confidence: Probable · As of 11 Jun 2026 · evidenced
    Evidence and sources

  • CAP said on 12 June 2025 that the CAP and BCAP Codes do not contain specific rules relating to AI and that marketers must ensure AI use does not breach the existing rules; there is no separate Code section for AI-generated or deepfake ads.

    Confidence: Confirmed · As of 12 Jun 2025 · evidenced
    Evidence and sources
    • "Write a useful article helping marketers with tips for using AI" (CAP News) T1 · retrieved · retrieved 8 Oct 2026 · CAP News 12 June 2025Whilst the CAP and BCAP Codes do not contain specific rules relating to AI at this time, marketers should ensure that their use of AI doesn’t generate an issue with the existing rules. Download the latest advice for marketers on using AI in ads.
    • In at the Deep(fake) End (CAP News) T1 · retrieved · retrieved 8 Oct 2026 · CAP News 8 February 2024, section "CAP Code vs Coding?"There isn’t a separate section of the CAP Code that deals with AI-generated ads. This means any ads the ASA might assess that use deepfake t
    • AI and Deepfakes: Four Things Advertisers Need to Know Before They Hit "Run" (CAP News) T1 · retrieved · retrieved 8 Oct 2026 · Point 1: The CAP Code is media-neutralAI might change how ads are made, but it doesn't change how they're regulated. The Code is media-neutral, meaning the rules apply regardless of how the content

  • CAP says an AI-generated celebrity endorsement that looks real enough to mislead consumers is likely to breach the Code, and that marketers must ensure deepfake content complies with the rules on misleadingness, testimonials and endorsements; personality and intellectual property rights are not ASA matters.

    Confidence: Confirmed · As of 11 Jun 2026 · evidenced
    Evidence and sources

  • Derived: Probable CAP says the advertiser remains responsible for any AI output used in its ads, and the ASA found that an advertiser was still primarily responsible for CAP Code compliance although the ad was produced with Google's automated tools.

    Confidence: Probable · As of 11 Jun 2026 · evidenced
    Evidence and sources

  • The ASA applies the CAP Code to ads within its remit, so AI-generated ads must comply with it; the guidance itself adds no new rule.

    Confidence: Probable · As of 11 Jun 2026 · evidenced
    Evidence and sources

  • Derived: Probable CAP said on 7 February 2025 that it is closely monitoring AI policy developments and that the rules in Section 6 of the CAP and BCAP Codes on depicting or referring to living persons would likely apply to generative AI replicas.

    Confidence: Probable · As of 7 Feb 2025 · evidenced
    Evidence and sources

  • Derived: Probable Part 4 of the Act (marketing restrictions), so far as not already in force, comes into force on 7 January 2027 under SI 2026/731 made 1 July 2026.

    Confidence: Confirmed · As of 7 Jan 2027 · evidenced
    Evidence and sources