Pennsylvania Implements Disclosure Requirements for AI-Generated Advertising

Pennsylvania is among the first states to mandate disclosures for AI-created content, applying the requirement regardless of where an advertisement was produced. Consequently, viewers outside the state may see these labels in commercials that are also scheduled to air in Pennsylvania.

The law contains several loopholes. The definition of “significantly modified” remains subjective, and exemptions apply to parody, satire, commentary, criticism, and material considered “evidently fictional”—terms the statute does not clearly define. Furthermore, the language suggests that disclosures are required only when synthetic content creates a false consumer perception about a product or service, leaving open questions about what qualifies as “false” and who has the authority to decide.

The office of State Senator Nick Pisciottano, who introduced the bill, did not immediately return a request for comment.

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