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The Philippines' Ad Standards Council, an industry self-regulatory body and not a government regulator, has required a clear AI disclosure on advertisements with content created, generated or materially enhanced by AI, effective 21 September 2026
The circular covers content created or generated with AI as well as content materially enhanced with AI, and it never says what "materially" means. An agency that retouches a product shot with an AI tool is left to judge for itself whether that counts as a material enhancement.
Bottom line: In effect from 21 September 2026. The issuer is an industry self-regulatory body, not a government regulator, and the circular does not state any statutory basis for the rules it sets. How far it reaches anyone outside the ASC's members and clients is not established.
Who this affects: Advertising and marketing counsel, creative, production and media agency leads, in-house brand compliance teams, and platform ad-policy staff handling advertising that runs in the Philippines.
Issue date: Dated 18 September 2026 and posted the same day. It took effect on 21 September 2026, three days later, with no transition period stated.
What changed: Under the ASC's self-regulatory circular, advertisements with content created, generated or materially enhanced through AI, in whole or in part, now carry a disclosure duty, and the circular states that reliance on AI does not excuse or mitigate any violation.
Analysis: In our reading, the disclosure is framed as neutral: the circular says it is not an admission that an ad is misleading. The practical risk sits in the undefined materiality threshold for enhanced content and in Section VII, which handles complaints and leaves open a Cease and Desist Order under ASC rules where sufficient grounds exist.
Primary sources: ASC Circular 2026-014, Guidelines on the Use of Artificial Intelligence in Advertising (PDF, 3 pages) · ASC web posting of Circular 2026-014, 18 September 2026
- Instrument (EN)
- ASC Circular No. 2026-014, Guidelines on the Use of Artificial Intelligence in Advertising
- Authority
- Ad Standards Council (ASC), Philippines. The circular prints the names of Robbie A. Aligada, Executive Director, and Erwin O. Furagganan, Ad Content and Operations Manager
- Jurisdiction
- Philippines, advertising industry self-regulation
- Status
- Issued 18 September 2026. In effect from 21 September 2026 under Section VIII
- Bindingness
- Self-regulatory. Section II says the circular applies to advertisers, agencies, production companies, digital platforms and all other persons involved in AI-assisted advertising; how far ASC rules reach a party outside its membership and client base is not established. It is not a statute or government regulation, and the circular states no statutory basis
- Issue date / next deadline
- Dated 18 September 2026. Effective 21 September 2026. No transition period or later deadline is stated
- Document
- Three page circular addressed to 4As / PANA / KBP / MSAP / UPMG / DMAP / OHAAP / Other ASC Clients
- Primary source
- https://asc.com.ph/wp-content/uploads/2026/09/ASC-Circular-2026-014-GUIDELINES-ON-THE-USE-OF-ARTIFICIAL-INTELLIGENCE-IN-ADVERTISING.pdf
What the disclosure clause requires
Section IV is the operative clause of this self-regulatory circular. It provides that advertisements "that contain content created, generated, or materially enhanced through the use of Artificial Intelligence (AI), whether in whole or in part, shall include a clear and reasonably conspicuous disclosure informing the audience that AI was used in the creation of the advertisement or of any material portion thereof."
The circular suggests wording without mandating it. The disclosure may use "AI-generated", "AI-assisted", "Created with AI", "Contains AI-generated content", or words of similar import that clearly communicate the use of AI.
Presentation has its own test: "reasonably noticeable, legible, and appropriate to the format of the advertisement whether in font size or as seen against a background." There is no minimum font size, duration or placement rule.
The threshold problem
Section III describes AI use very broadly. It includes generating, enhancing, modifying or manipulating text, images, audio, video, animation or voice, and "the use of AI-assisted tools in the development, production, or post-production of advertising materials."
The disclosure duty in Section IV is narrower. It attaches to content "created, generated, or materially enhanced" through AI. The circular does not define "materially", and it gives no examples.
An AI tool used to clean up background noise falls inside Section III's description of AI use, and whether that is a material enhancement is left open by the text. An AI tool used to generate a model's face is a different case: that is content generated through AI, which falls within Section IV's first two triggers without any question of materiality. That reading is ours.
Disclosure is not an admission that an ad misleads
The circular goes out of its way to separate disclosure from wrongdoing. Section III says the use of AI, "by itself", does not render an advertisement misleading, deceptive or otherwise non-compliant. Section IV says the disclosure is intended "solely" to promote transparency and "shall not, by itself, be construed as an indication that the advertisement is misleading".
The same sections keep existing obligations in place. Using AI does not exempt anyone from existing laws or ASC standards, and where other rules already require disclosures, authorisations or consents arising from AI use, advertisers are to comply with those too. Section IV lists minors in advertising, AI depictions of identifiable real persons including public figures, intellectual property, and use of buildings or other protected structures.
Responsibility stays with the advertiser
Under Section V of the self-regulatory circular, advertisers and other responsible parties "shall exercise appropriate human oversight and professional judgment in the use of AI in advertising". The same section says advertisers "remain fully responsible for all claims, representations, depictions, endorsements, and other content appearing in advertisements, regardless of whether such content was created by humans, AI, or a combination of both."
Section V then states: "Reliance on AI shall not excuse or mitigate any violation of applicable laws, rules, regulations, or advertising standards."
Section VI adds that the circular does not limit, amend or supersede existing law. Where an AI-assisted advertisement falls within an already regulated activity, those legal requirements continue to govern.
Who issued it, and how far it reaches
The ASC is not a government agency. Its own website describes it as "a self-regulating, independent, non-profit organization" that screens ad content across media in the Philippines. The circular itself does not cite any statute or government delegation.
Section II sets a wide scope on paper: advertisers, creative agencies, production companies, media agencies, digital platforms and "all other persons or entities" involved in AI-assisted advertising. The address line is narrower, naming seven groups by acronym and "Other ASC Clients". We have not established how the ASC's rules reach a party outside its membership and client base, and we do not claim they do.
Section VII deals with complaints. Under it, where a complaint is filed with the ASC over alleged misuse or unlawful use of AI-generated or AI-assisted content, the ASC "may require" the responsible party to address or resolve it with the complainant, without prejudice to other action under its rules. It also says nothing in the circular precludes the ASC from issuing a Cease and Desist Order or taking other action under its rules "where sufficient grounds exist". It does not say a CDO follows automatically.
What we did not verify
What we opened: the three page PDF of Circular 2026-014 downloaded from the ASC website, and the ASC web posting of the same circular dated 18 September 2026. The texts match in substance. The web posting renders one phrase as "Contains AIgenerated content" where the PDF hyphenates it, and its title spells Guidelines as "Guidlines"; we followed the PDF. We also read the ASC homepage for its description of itself, retrieved again on 24 September 2026.
What we did not open: the ASC Code of Ethics, the ASC rules and procedures on complaints and Cease and Desist Orders that Section VII refers to, and any Philippine statute or government issuance that might bear on the ASC's authority. So we do not state what sanctions follow a CDO, or whether any government body recognises or enforces this circular.
What we refuse to claim: we do not call the ASC a regulator or the circular a law, and we do not claim it binds persons outside the ASC system. We do not say any particular AI use is or is not a material enhancement, because the circular does not define the term. Quoted disclosure wording uses ASCII quotation marks in place of the typographic marks in the PDF, a house typesetting convention that changes no word.
Informational analysis for working professionals, not legal advice. Confirm how any rule applies to your situation with qualified counsel.
The circular is already in effect, and one branch of its trigger, material enhancement, turns on a word it does not define. Agencies and advertisers running work in the Philippines should decide, and write down, what they treat as a material AI enhancement, who checks that the disclosure is legible in each format, and who signs off on AI depictions of real people, since Section V leaves full responsibility with the advertiser whatever tool produced the content.
Source File
Open the three page PDF. Read Section IV for the disclosure trigger and wording, Section V for advertiser responsibility, Section VII for complaints and Cease and Desist Orders, and Section VIII for the 21 September 2026 effective date.
In the interest of transparency, advertisements that contain content created, generated, or materially enhanced through the use of Artificial Intelligence (AI), whether in whole or in part, shall include a clear and reasonably conspicuous disclosure informing the audience that AI was used in the creation of the advertisement or of any material portion thereof. ยท ASC Circular No. 2026-014, Section IV, 18 September 2026
FAQ
When does the circular apply from?
Section VIII says it took effect on 21 September 2026. The circular is dated 18 September 2026 and states no transition period.
Does using AI make an ad misleading under the circular?
No. Section III says the use of AI by itself does not render an advertisement misleading or noncompliant, and Section IV says the disclosure is not by itself an indication that the ad is misleading.
Is the Ad Standards Council a government regulator?
No. The ASC describes itself as a self-regulating, independent, non-profit organization. The circular does not cite a statutory basis for its rules.
What can the ASC do if someone complains?
Under Section VII it may require the advertiser, agency or other responsible party to address or resolve the matter with the complainant, and nothing in the circular precludes it from issuing a Cease and Desist Order where sufficient grounds exist.
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