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What You Must Disclose to Customers About Your Use of AI

Disclosure requirements for AI are expanding in nearly every jurisdiction. What was optional transparency two years ago is becoming a legal obligation — and the businesses that built disclosure into their customer experience early are better positioned.

Ravve Jay Prevendido
Ravve Jay Prevendido·Jun 13, 2026·4 min read
17+ industry awards · Brand architect behind OWWA, Nuvia & 100+ brands · ravvejay.com
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What You Must Disclose to Customers About Your Use of AI

Picture three companies. One uses AI to score support tickets and route them by urgency. Another uses AI to rank job applications before any human sees them. A third uses AI to write product descriptions on its store. In every case, the people involved deserve to know AI is at work. Customers, applicants, and shoppers should know what role it plays. And the ai disclosure requirements business owners face are growing fast. In more and more cases, the law now demands you tell them.

The rules for AI disclosure are splitting fast across regions. The EU AI Act sets broad rules for high-risk AI systems. The Colorado AI Act adds notice duties for major automated decisions. FTC guidance targets deceptive AI claims. And the law is only the floor. Customer expectations are rising too. Some firms treat transparency as a trust signal, not a chore. Those firms are building a lasting brand edge.

This piece is not legal advice. Your counsel should review your own duties. Those depend on your location, your product type, and your use case. What follows is a practical framework instead. It helps business leaders see what disclosure looks like in the areas most likely to touch them.

Automated and AI-assisted decisions affecting individuals

The strongest disclosure rules apply to one kind of system. These are automated systems that make or heavily shape decisions about people. The list includes credit decisions, insurance underwriting, and employment screening. It also covers tenant screening and medical triage. The EU AI Act calls most of these "high-risk" AI systems. It requires three things. First, clear notice that an automated system is involved. Second, real information about the system's role. Third, in many cases, the right to a human review of the decision.

The CFPB has issued guidance in the United States. It says lenders who use AI models for credit decisions must explain adverse actions. They must give the main reasons in terms a consumer can understand. That duty sits in tension with opaque, black-box models. Your liability exposure when AI makes a mistake only grows when you skip disclosure. Regulators often read non-disclosure as a sign of bad faith.

Disclose that an AI or automated system was involved in any consequential decision about the individual.

Explain, in plain language, what the system evaluated and how it influenced the outcome.

Provide a mechanism to contest the decision and request human review.

Retain documentation of the decision rationale sufficient to explain it if challenged.

AI-generated content and synthetic media

AI-generated content sits in a grayer zone. Think of product descriptions, customer emails, support replies, and social posts. Most regions do not yet require you to label text as AI-written. That differs from AI-decided. Still, the FTC sets endorsement guides and bans deceptive practices. So you face real risk if AI content makes false, misleading, or unproven claims. The practical rule is simple. Disclose when staying silent would mislead.

Synthetic media and AI avatars need clearer disclosure. Several U.S. states now have laws here. They require you to disclose AI-generated video or audio in commercial and political settings. Even where the law is silent, the risk is real. Using a synthetic voice or AI likeness for your brand without notice can break trust. That cost almost always beats the cost of being open.

Chatbots and AI-assisted customer service

Many states and the EU's proposed rules share one requirement. Consumers must be told when they are dealing with an automated system, not a human. They must also be able to ask for a human agent. That is the minimum standard. The best design goes further. It makes the AI's role and limits clear. Then users set the right expectations. They trust the chat instead of feeling fooled when they learn it was a bot.

There is a set of questions business leaders should ask before deploying AI. Disclosure design is one of them. How will you tell customers what they are dealing with? And how will you offer recourse when the AI cannot help?

Best-practice disclosure beyond the legal minimum

Some firms build the strongest customer relationships around AI. They treat transparency as a brand asset, not a checkbox. In practice, that means a few clear habits. They disclose AI use up front at customer touchpoints. They explain in plain language what the AI does and does not do. They offer clear paths to recourse. And they publish an AI use policy customers can read. TTGC recommends this to every client using AI with customers. Transparency is not a cost. It is a trust asset.

TTGC builds disclosure frameworks into every AI product the studio ships. These are not boilerplate terms-of-service lines. They are customer-experience features instead. Notices appear right at the decision point. Plain-language notes explain how the system works. And the recourse paths are truly usable, not just technically present. Some industries carry their own compliance duties. Healthcare, fintech, and HR each need extra frameworks. Those are covered in the sector pieces on healthcare AI accountability and fairness in lending.

Some firms treat AI disclosure as a burden. They optimize for the bare minimum. Others treat it as a brand signal. They build a relationship that compounds over time.

Building AI into your customer experience? Talk to TTGC about disclosure frameworks that protect your business and build trust.

Book a free Brand and Growth Assessment and see exactly how Through The Glass Creatives would approach it.

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Sources

  1. European Parliament - "EU Artificial Intelligence Act" (2024). Disclosure requirements for high-risk AI systems.
  2. U.S. Consumer Financial Protection Bureau - "CFPB Circular 2022-03: Adverse Action Notification Requirements and the Equal Credit Opportunity Act" (2022).
  3. U.S. Federal Trade Commission - "FTC Report on Artificial Intelligence: Using AI to Harm People" (2022). Consumer protection standards for AI systems.
  4. Colorado General Assembly - "Colorado Artificial Intelligence Act" (2024). State-level AI disclosure and consumer protection requirements.
  5. OECD - "OECD AI Principles" (2023). International standards for transparency and explainability in AI systems.

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