AI advertising clearance workflow

Clear the person, the proposed use and the actual output as three connected decisions. A release in a folder is not enough if nobody can tie it to the file that ships.

Gate one: before sourcing or capture

Gate two: before generation

Gate three: before publication

The FTC states that endorsements must be truthful and not misleading, and that material connections which could affect how consumers evaluate an endorsement should be disclosed. Identity permission does not replace those advertising obligations.

Source: Federal Trade Commission, advertisement endorsements.

Gate four: client handoff and change control

The stop rule

If the identity, permission, production plan and output evidence do not join up, stop before publication. Resolve the missing record rather than asking a disclosure label or AI tool contract to carry rights it does not contain.

Bring a clearance briefReview the clause map

This workflow supports a commercial review. It is not legal advice or a substitute for campaign counsel, union requirements, platform rules or jurisdiction-specific clearance.

Common questions

What should an agency clear before generating an AI likeness?

Confirm the real person, their authority, the exact intended use, asset version, generation route, approvals, term and secured payment before generation begins.

Are the AI tool’s terms enough to clear the person?

No. Tool terms govern the tool relationship. Permission from the identifiable person must be established separately.

What should the client receive?

The client handoff should include the signed agreement hash, scope, term, asset version, current licence status and a receipt for each registered release.

What happens when the campaign changes?

Compare the change with the signed scope. A materially different use or anything outside scope needs fresh review and permission before production continues.