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How to Write an AI Content Disclosure Policy

A short, practical guide to putting something in writing — plus a template you can adapt in ten minutes — so "do you disclose AI use?" has a real answer instead of a shrug.

Most agencies using AI don't have a written policy on it. They have habits — someone drafts with ChatGPT, someone else checks it, nobody writes down who or when. That's fine until a client asks directly, or a contract requires it, or a regulator does. A one-page policy fixes that, and it's genuinely a ten-minute job once you know what to include.

What a policy needs to cover

Keep it short. A disclosure policy that's actually followed beats a thorough one that sits in a drawer. Six things, at minimum:

  1. Which AI tools are approved for client work. Name them. "AI tools" as a category is too vague to be useful when someone asks later.
  2. What counts as AI-assisted vs. AI-generated. Draw the line once so your team isn't guessing case by case — this maps directly to the three-tier scale most disclosure formats use: AI-generated, AI-assisted, human-created/AI-reviewed.
  3. When human review is required before delivery. Ideally: always. State it as a rule, not an assumption.
  4. Who signs off, and how that's recorded. A name and a date, every time. This is the single most valuable line in the whole policy — it's what turns "someone probably checked it" into an actual record.
  5. When and how you disclose to the client. Every deliverable? On request? Only above a certain AI-involvement threshold? Decide once, apply consistently.
  6. Where the records live. A folder, a shared sheet, a tool. It doesn't need to be sophisticated — it needs to exist and be checkable later.
Why item 4 carries the most weight Under EU AI Act Article 50, AI-generated content that's undergone genuine human editorial review is exempt from certain disclosure requirements — but only if you can show that review happened. A policy that makes sign-off automatic and recorded isn't just good practice, it's the thing that makes that exemption actually usable. See our plain-language breakdown of Article 50 for the detail.

The legal backdrop, briefly

Requirements vary by where your clients and their audiences are, and the picture is genuinely uneven right now:

WhereStatus
EU (AI Act Art. 50)In force since Aug 2, 2026. Applies to "deployers" using AI professionally; strongest obligation is disclosing AI-generated text on public-interest matters, with a human-review exemption.
Texas (TRAIGA)In force since Jan 1, 2026. Disclosure required for AI-driven consumer interactions.
ColoradoOriginal 2024 AI Act repealed and replaced by a narrower transparency/disclosure law; obligations begin Jan 1, 2027.
California (SB 942)Operative Aug 2, 2026. Targets large GenAI platform providers (1M+ monthly users) directly — most agencies using third-party tools aren't directly covered, though the tools you use may be.
FTC (US, general)No AI-specific disclosure statute, but active enforcement against undisclosed AI use under existing deceptive-practices authority.

None of this is a substitute for legal advice specific to your situation — the point of the table is just to show why "one policy, applied consistently" beats trying to track every jurisdiction separately.

A template you can adapt

Copy this, fill in the brackets, done:

1. Approved AI tools: [list tools by name]
2. AI-Generated = AI produced the substantial majority; human role was review only.
   AI-Assisted = AI contributed significantly; human substantially edited or directed.
   Human-Created, AI-Reviewed = human created it; AI used only for review/research/QC.
3. Human review is required on 100% of AI-generated or AI-assisted deliverables before client delivery.
4. Sign-off is recorded for every deliverable: reviewer name, role, date.
5. Disclosure to clients: [every deliverable / on request / above X% AI involvement — pick one]
6. Records are kept in: [your system], retained for [duration].

Item 4 and 6, handled in one step

DisclosureTrail generates the sign-off record for you — tool used, involvement level, reviewer, dates — as a client-ready statement. Free, no login, nothing stored on our end.

Generate a disclosure statement →