AI Transparency and Disclosure
When and how to disclose AI tool usage to clients, and what “substantial use” means in practice.
Key points
- Disclose AI use when it forms a substantial part of your process or output
- ‘Substantial’ usually means AI-generated content (rather than research, ideation or editing)
- If in doubt, disclose. Transparency helps to build trust with your clients and collaborators
- Document your AI use for your own records
What the Code says
The ProCopywriters Code of Conduct requires that you “disclose any substantial use of AI tools in your work when relevant to the client relationship.”
So what does substantial mean, and when is disclosure relevant?
This guidance helps you interpret and apply this element of the code. The goal is to strengthen the trust between copywriters, clients and collaborators.
Why transparency matters
You may wonder why transparency is required. After all, if the copy is great, does it matter how it was created?
There are three reasons why authorship matters.
Your professional obligation
Clients hire copywriters because they want the expertise, judgment, skills and creative talent that you offer – they don’t just want words on a page. If AI generated most of the words, and your involvement is limited to prompting and light editing, the client has a right to know. This isn’t about whether AI can write well; it’s about being honest about what you’re delivering.
Your client’s risk
Publishing AI-heavy content can bring unexpected risks – risks that clients may be unaware of if they believe their content was produced by human hands. Clients need to know how their content was created so they can manage the related risks:
Copyright confusion
In some jurisdictions, the copyright status of AI-generated content is yet to be defined. Content produced largely by AI may be exempt from the copyright protections afforded to human-authored work.
Regulatory risk
In some regulated sectors, such as healthcare, legal, and financial services, authorship can be a relevant factor. Undisclosed AI authorship could create problems for your clients.
Audience relationships
Multiple studies have found that readers are turned off by content they perceive to be AI-generated. Clients need to make informed decisions about how and when they offer AI-generated content, so it’s important they know how their content was produced.
Reputation risk
If your client is found to have used AI to generate content or copy, then any regulatory or reputational impact will fall on them.
Anticipating the future of AI regulations
AI disclosure requirements are only increasing as the world becomes familiar with the opportunities and risks of generative AI.
The EU AI Act will require disclosure of AI-generated content from August 2026. Google is increasingly able to identify content produced without human expertise. Professional standards in adjacent fields are moving towards transparency by default.
It’s about informed decisions
The ProCopywriters policy on AI isn’t about demonising AI tools; it’s about ensuring your clients and collaborators have the information they need to make their own decisions – decisions that can have legal and reputational consequences.
What counts as substantial use?
Not every interaction with an AI tool requires disclosure.
Generally doesn’t require disclosure:
- Research or fact-checking
- Grammar and spell-checking
- Generating ideas and brainstorming
- Transcription
- Translation tools for background tasks
Generally requires disclosure:
- AI-generated drafts that you edit and improve
- Using AI to write significant parts of deliverables
- AI-generated material that appears in the final draft without significant changes
- Using AI to create content variations
Does it matter?
If you’re unsure whether your AI use is relevant to the client, ask yourself: if the client knew exactly how you’d used AI, would it change their perception of the work or its value? Or would it affect the decisions they made about the content, such as how they present it, where they publish it, or how they manage copyright? If the answer is yes, then you should disclose.
When to talk about AI use
Talk to your clients and collaborators early on in project discussions. You’ll want to understand how they feel about AI, whether it could affect the regulations they must follow, and whether it conflicts with any of their own policies.
Consider sharing your approach to AI in:
- Terms and conditions
- Project proposals and quotes
- Contracts
- Website and marketing materials
- Client conversations
Initiating conversations about AI use lets you address any client concerns and present your position as a professional choice.
Define your AI use
Having a simple statement that explains your approach to AI is a useful asset, one you can add to your website. It can be as simple as: “I use AI tools for research and brainstorming. All copy and content is written and edited by me, and I disclose any substantial AI contribution to specific projects.”
See also: AI Policy Template
How to frame AI disclosure
When you disclose AI use, frame it professionally:
Focus on value, not apology
AI is one of many tools that copywriters use. Explain how you use AI to achieve better results – accelerated research, broader ideas, challenged assumptions, or more time for strategic thinking.
Be clear about your role
Clarify your contribution to the work. “I used AI to produce research summaries and to build customer profiles, then wrote all final content myself” is clearer than “I used AI on elements of this project”.
Respect client preferences
Your clients may have policies governing AI use, so it’s important to raise the issue early in the relationship. Given the potential risks connected with unauthorised AI use, as outlined above, client requests must be respected.
Check contractual obligations
Your contract may explicitly prohibit the use of AI. Check your agreements to ensure you’re not breaching the terms.
Watch for contractual restrictions
Some contracts explicitly prohibit AI use or require disclosure. Breaching these terms could have legal and reputational consequences.
Keeping records
Even when disclosure isn’t required, it’s good practice to document your AI usage. This will ensure you can answer any questions that may arise, but it’s also good practice for tracking your own tools, processes and performance.
Record:
- Which tools you used and for what purpose
- The extent to which AI contributed to the project
- How you verified and edited any AI-generated material
- Client conversations and agreements regarding AI use