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What an AI presenter can and can’t say

AI presenters are a fast way to make UGC-style ads. They also make it easy to break the rules on testimonials without noticing. Here’s where we draw the line, and why.

Still from a Lumivance spec ad: a presenter talks to camera, then lifts the watch from its case
Still from a Lumivance spec ad: a presenter smiles at a rose-gold watch, then tries it on
Stills from our spec ads, made with AI.

The short version

An AI presenter can demonstrate a product, explain what it does and recommend it in the brand’s voice. It can’t pretend to be a customer who used the product and got results.

What the FTC rule says

In 2024 the US Federal Trade Commission finalized a rule banning fake consumer reviews and testimonials, including ones that claim to come from people who don’t exist, such as AI-generated ones, or from people who never actually used the product. It took effect in October 2024.

Rules elsewhere differ in detail but point the same way: an endorsement has to reflect a real person’s honest experience.

What that means for UGC-style ads

The line is between showing and claiming:

  • “Here’s how this serum goes on.” A demonstration. Fine.
  • “It’s fragrance-free and made for sensitive skin.” A product claim. Fine, if it’s true.
  • “I’ve used this every morning for a month and my skin has never been clearer.” A testimonial from someone who doesn’t exist. Not fine.

Real reviews, used properly

If you have genuine customer reviews, they can appear in an ad as on-screen quotes credited to the customer, with their permission. They shouldn’t be read out by a generated person posing as the reviewer.

Platform labels

Meta and TikTok both have rules for labeling realistic AI-generated content, and both review the claims in every ad. We follow their current rules and tell you which ads need a label before they go live.

This isn’t legal advice

It’s how we work and why. Your own counsel has the final word on your claims and disclosures.

Want to see what we’d test first?

Tell us what you sell and what you’re running now. We’ll come back with the angles we’d test first and what it costs.