Introduction
Artificial intelligence has rapidly transformed the advertising industry. Brands can now create realistic digital characters, virtual influencers, synthetic voices, AI-generated product visuals, automated advertising texts, deepfake-style videos, personalized advertising scenarios and digital copies of real persons. These technologies allow businesses to produce faster, cheaper and more creative advertising campaigns. However, they also create new legal risks, especially when consumers cannot understand whether the person, image, voice or experience presented in an advertisement is real.
The subject of AI-generated advertisements under Turkish advertising law has become one of the most important topics in digital marketing compliance in Turkey. Artificial intelligence is no longer only a technical tool used behind the scenes. It is now directly visible in advertisements and may influence consumer decisions by creating human-like characters, simulated experiences, virtual endorsements and personalized persuasive messages.
Turkish advertising law is based on consumer protection, truthfulness, transparency and prevention of unfair commercial practices. These principles apply to all advertisements, regardless of whether they are created by humans, agencies, software tools or artificial intelligence systems. Therefore, an AI-generated advertisement is not exempt from advertising law simply because it is produced by technology. If the advertisement misleads consumers, hides its commercial nature, creates a false endorsement impression or uses a digital copy of a real person unlawfully, it may trigger legal and administrative sanctions.
The importance of this issue increased significantly with the amendments to the Regulation on Commercial Advertising and Unfair Commercial Practices published in the Official Gazette on 1 July 2026. According to the Ministry of Trade, these amendments introduced new rules in several areas, including targeted advertising, social media influencer promotions, discount advertising and advertisements created with artificial intelligence. The Ministry expressly stated that where advertisements use artificial intelligence technologies to include digital characters that cannot be distinguished from real humans, this must be clearly, understandably and distinguishably disclosed. It also stated that advertisements using the AI-generated digital copy of a real person in a way that creates the impression that the person personally experienced or recommended a product or service are prohibited.
This article explains the legal framework of AI-generated advertisements in Turkey, disclosure obligations, misleading advertising risks, deepfake endorsements, virtual influencers, personal rights, data protection issues, sector-specific risks, Advertising Board sanctions and practical compliance steps for businesses.
Legal Framework of AI-Generated Advertising in Turkey
AI-generated advertisements are mainly regulated within the broader framework of Turkish consumer protection and advertising law. The key legal sources are Law No. 6502 on the Protection of Consumers and the Regulation on Commercial Advertising and Unfair Commercial Practices. These rules require advertisements to be honest, accurate, clear, transparent and compliant with consumer protection principles.
The Advertising Board, known in Turkish as the Reklam Kurulu, is the main administrative authority responsible for supervising commercial advertisements and unfair commercial practices. The Ministry of Trade describes the Advertising Board as the only administrative authority authorized to examine and supervise commercial advertisements and unfair commercial practices directly or indirectly targeting consumers in any medium. The Board may impose suspension, correction, administrative fines, temporary suspension and access blocking measures for unlawful advertisements.
The 2026 amendments specifically brought AI-generated advertisements into the regulatory agenda. According to the Ministry of Trade, the purpose of the amendments is to strengthen consumer protection in an environment where digitalization exposes consumers to more advertisements and commercial listings. The new rules cover AI-generated advertisements together with targeted advertising, influencer promotions, discount advertisements, environmental claims and consumer reviews.
This means that AI advertising compliance in Turkey should be evaluated under several legal layers. First, the advertisement must comply with general advertising law principles. Second, the advertisement must not mislead consumers. Third, AI use must be disclosed where required. Fourth, if the advertisement uses the image, voice, name, likeness or digital copy of a real person, personality rights and consent issues must be assessed. Fifth, if personal data is processed for targeting or personalization, data protection law may also apply.
What Are AI-Generated Advertisements?
AI-generated advertisements are commercial communications created, modified, personalized or enhanced through artificial intelligence technologies. They may be fully generated by AI or only partially supported by AI. The form of the content is not decisive. What matters is whether artificial intelligence is used in a way that affects the advertisement’s message, visuals, voice, characters, endorsement or consumer perception.
Examples of AI-generated advertisements include virtual influencers promoting products on social media, synthetic human models appearing in video commercials, AI-generated voices reading advertising scripts, deepfake-style celebrity endorsements, product images generated without real photography, automated personalized advertising texts, AI-created customer testimonials, realistic digital avatars presenting services, and AI-generated before-and-after visuals.
AI may also be used to create dynamic advertising content. For example, a platform may generate different product recommendations, visuals, text or offers for different users based on their behavior, location, interests or purchase history. In such cases, AI-generated advertising may overlap with targeted advertising and personal data protection issues.
From a legal perspective, the most important question is whether the AI-generated element may mislead the average consumer. If the consumer believes that a digital character is a real human, that a celebrity personally endorsed a product, that a product result is real, or that a testimonial reflects genuine consumer experience, the advertisement may create legal risk.
Core Legal Principles Applicable to AI Advertisements
The first principle is truthfulness. AI-generated advertisements must not contain false or deceptive information. A brand cannot use AI to fabricate product results, create unrealistic performance visuals or generate testimonials that do not reflect real consumer experiences.
The second principle is transparency. Consumers must be able to understand when the advertisement uses artificial intelligence in a way that affects their perception. The 2026 amendments specifically require clear disclosure when AI-generated digital characters cannot be distinguished from real humans.
The third principle is substantiation. Claims in AI-generated advertisements must be provable. If an AI-generated advertisement says that a product is “clinically proven,” “number one,” “the most effective,” “doctor recommended,” “environmentally friendly” or “guaranteed,” the advertiser must have reliable evidence. The fact that the statement was produced by AI does not reduce the advertiser’s responsibility.
The fourth principle is fairness. AI must not be used to manipulate vulnerable consumers, exploit fears, create false urgency, imitate trusted persons or distort consumer autonomy. This is particularly important in advertisements directed at children, elderly consumers, patients or financially vulnerable individuals.
The fifth principle is respect for personal rights. If an advertisement uses the digital copy, image, voice, face, name or likeness of a real person, the advertiser must consider consent, personality rights, reputation, privacy and intellectual property issues. AI-generated content can easily create unauthorized association with a person, celebrity, professional, doctor, influencer or ordinary consumer.
Disclosure Obligation for AI-Generated Digital Characters
One of the most important new rules concerns AI-generated digital characters. The Ministry of Trade announced that if advertisements include digital characters created with artificial intelligence technologies that cannot be distinguished from real humans, this must be clearly, understandably and distinguishably indicated.
This rule aims to prevent consumers from believing that a fully artificial character is a real person. In many advertisements, the perceived credibility of a person matters. A consumer may trust a realistic-looking person who appears to have used a product, visited a clinic, tried a service or experienced a result. If that person is actually an AI-generated character, the consumer should know this.
The disclosure should be visible and understandable. It should not be hidden in small print, placed at the end of a long video, buried in a website footer or written in technical language. The disclosure should be presented in a way that an average consumer can notice at the time the advertisement is viewed.
For example, if a brand uses a virtual human to promote a skincare product, the advertisement should clearly state that the character is AI-generated. If a digital presenter appears in a video advertisement, the consumer should understand that the presenter is not a real person. If a virtual influencer promotes a product on social media, the artificial nature of the influencer should not be concealed.
Prohibition of False Experience and Recommendation by Digital Copies
The second key rule concerns digital copies of real persons. The Ministry of Trade stated that advertisements using an AI-generated digital copy of a real person in a way that creates the impression that the person personally experienced or recommended a product or service are prohibited.
This rule is highly important for deepfake advertising. AI technologies can now reproduce a person’s face, voice, gestures and style with high realism. A brand may be tempted to create an advertisement where a celebrity, doctor, influencer, athlete, customer or public figure appears to recommend a product. If the person did not genuinely experience or recommend the product, such advertising may mislead consumers.
The prohibition is not limited to famous persons. It may also apply to ordinary individuals whose image, voice or likeness is digitally copied. For example, using a former customer’s face to create an AI-generated testimonial without genuine experience may be unlawful. Similarly, using a doctor’s digital copy to imply medical approval may create serious advertising and professional regulation risks.
Even where the person has given some form of consent to use their likeness, the advertisement must not mislead consumers about the nature of the experience or recommendation. Consent to use an image does not necessarily justify creating a false impression that the person personally used or endorsed a product.
AI Influencers and Virtual Brand Ambassadors
Virtual influencers are becoming increasingly common in global advertising. These are fictional digital personalities created through design, animation, artificial intelligence or mixed technologies. They may post on social media, interact with followers, promote products and participate in brand campaigns.
In Turkey, virtual influencers may be used in advertising, but transparency is essential. If the influencer is not a real human, consumers should not be misled into believing otherwise. If artificial intelligence is used to create a digital character that cannot be distinguished from a real person, the AI-generated nature of the character must be disclosed clearly.
Virtual influencers also create sponsorship disclosure issues. If a virtual influencer account promotes a brand, product or service, the commercial nature of the post should be clear. The general principles applicable to influencer marketing and sponsored content still apply. A virtual influencer should not present commercial content as independent personal experience.
Brands should also be careful with storytelling. A virtual influencer may have a fictional personality, lifestyle and background. However, fiction should not be used to create false product experiences. For example, a virtual influencer should not claim “I used this supplement and lost weight,” “this clinic treated me,” or “this device helped me recover” if the experience is not real and the claim may mislead consumers.
AI-Generated Testimonials and Consumer Reviews
Consumer testimonials are powerful advertising tools. Consumers often trust statements that appear to come from other users. AI-generated testimonials can therefore create serious legal risk.
A business should not use AI to create fake consumer reviews, fake customer experiences or artificial satisfaction statements. If an advertisement includes a testimonial, it should reflect a genuine, verifiable experience. AI should not be used to fabricate consumer opinions or to generate misleading review patterns.
This issue is connected to the 2026 amendments concerning consumer reviews. The Ministry of Trade stated that consumer reviews obtained from platforms where purchase verification is not possible may not be published, and where reviews are categorized under headings such as product, service, delivery, seller or provider, all reviews must be presented clearly and accessibly in the same area.
Although this rule is not limited to AI, it is highly relevant to AI-generated review manipulation. AI tools can generate large numbers of realistic reviews quickly. Businesses should not use such tools to inflate ratings, create fake consumer satisfaction, suppress negative impressions or mislead consumers about market reputation.
AI-Generated Visuals and Product Performance
AI-generated visuals may also mislead consumers about product characteristics. A product image, before-and-after comparison, beauty result, fitness transformation, home design render, food presentation, travel destination or real estate project may appear more attractive when generated or enhanced by AI.
Using AI visuals is not automatically unlawful. However, if the visual creates a false impression about the actual product or service, it may violate Turkish advertising law. For example, an AI-generated image of a hotel room should not show facilities that do not exist. A real estate project advertisement should not use AI visuals to imply completed amenities that are not planned or legally available. A cosmetic product advertisement should not use AI-enhanced skin results that the product cannot realistically produce.
The same principle applies to product packaging, size, color, texture and functionality. If AI-generated visuals materially change how the product appears, the advertisement should be reviewed carefully. A disclaimer may be necessary in some cases, but a disclaimer may not be sufficient if the dominant impression remains misleading.
AI Voice Cloning and Synthetic Audio Ads
AI voice cloning creates another risk area. A synthetic voice may imitate a real person, celebrity, presenter, doctor, influencer or brand ambassador. If consumers believe that a real person spoke in the advertisement, the advertisement may create false endorsement risk.
Where a real person’s voice is used or imitated, permission and personality rights must be considered. Even if the voice is not an exact copy, a synthetic voice that strongly evokes a specific person may create legal and reputational issues. Brands should avoid using AI-generated voices that imitate recognizable persons without clear consent and proper disclosure.
Synthetic audio can also mislead consumers in radio ads, podcasts, social media videos, call center promotions, automated sales messages and voice-based digital assistants. If the AI voice appears to be a real expert or consumer, the advertisement should not create false trust.
AI-Generated Advertisements and Misleading Advertising
Misleading advertising is one of the main risks of AI-generated ads. An advertisement may be misleading if it contains false information, omits essential information, exaggerates product benefits or creates a deceptive overall impression. AI can increase this risk because it can produce realistic content that looks authentic even when it is artificial.
For example, an AI-generated advertisement may show a person experiencing immediate health benefits from a product. It may show a digitally created home renovation result that cannot be achieved with the advertised service. It may generate a “doctor-like” character recommending a product. It may create a fake customer story or a simulated “real user” video.
The Advertising Board evaluates advertisements and unfair commercial practices directed at consumers. The Ministry of Trade explains that unfair commercial practices include practices that do not comply with professional diligence and significantly distort, or are likely to distort, the economic behavior of the average consumer or the average member of the targeted group. Misleading or aggressive practices are considered unfair and prohibited.
Therefore, AI-generated content should be assessed from the perspective of the average consumer. The key question is not only whether AI was used, but whether the advertisement causes consumers to make decisions based on a false impression.
AI, Targeted Advertising and Personal Data
AI-generated advertising often overlaps with targeted advertising. AI systems may analyze consumer behavior, purchase history, browsing patterns, location, interests and demographic data to generate personalized ad content. This creates both advertising law and data protection concerns.
The 2026 amendments introduced rules on targeted advertising. According to the Ministry of Trade, advertisers may conduct targeted advertising if they provide consumers with direct and easily accessible information about the criteria used to show the advertisement and how those criteria can be changed. The same amendments prohibit targeted advertising directed at children through profiling based on personal data.
Where AI is used to personalize advertising content, businesses should consider whether consumers understand why they are seeing that advertisement. They should also evaluate whether personal data is processed lawfully, whether explicit consent is required, whether privacy notices are sufficient and whether consumers can change their advertising preferences.
AI-based personalization may become legally risky if it exploits vulnerabilities. For example, targeting financially distressed consumers with aggressive loan advertisements, patients with unverified treatment claims, or children with personalized product promotions may create serious compliance concerns.
AI-Generated Ads Directed at Children
Children are a vulnerable consumer group. They may have difficulty distinguishing between real and artificial characters, entertainment and advertising, or fictional stories and commercial persuasion. AI-generated characters may be especially persuasive for children because they can be designed to appear friendly, relatable and emotionally engaging.
Turkish advertising law already requires special care in advertisements directed at children. The 2026 amendments also prohibit targeted advertising directed at children through profiling based on personal data.
Businesses using AI-generated characters in children’s content should be extremely careful. A virtual character in a game, animation, educational app or video platform should not manipulate children into purchases, in-app spending or pressure on parents. AI-generated advertising should not exploit children’s inexperience, trust or emotional attachment.
Sector-Specific Risks in AI Advertising
AI-generated advertisements may create greater risk in sensitive sectors. Healthcare, cosmetics, food supplements, financial services, education, real estate, insurance and investment products should be reviewed carefully.
In healthcare and wellness advertising, AI-generated doctors, patients, before-and-after visuals or treatment stories may mislead consumers. A digital doctor-like character may create an impression of professional medical approval. A fake patient experience may suggest treatment effectiveness without legal basis. These practices may violate both advertising law and sector-specific rules.
In cosmetics and beauty advertising, AI-enhanced skin, hair or body results may create unrealistic expectations. If filters, digital retouching or AI-generated transformations exaggerate the product effect, the advertisement may be misleading.
In financial advertising, AI-generated success stories or simulated investment results may create false expectations. A digital character should not imply guaranteed profit, risk-free investment or personal financial success without lawful and clear disclosures.
In real estate advertising, AI-generated visuals should not show facilities, views, interiors or project features that do not exist or are not guaranteed. Consumers should understand whether visuals are illustrative, conceptual or based on actual project plans.
Advertising Board Sanctions
The Advertising Board may impose sanctions for unlawful AI-generated advertisements if they violate advertising law, mislead consumers or constitute unfair commercial practices. The Board may order suspension, correction, administrative fines, temporary suspension and access blocking for unlawful online advertisements.
Administrative fines can be substantial. For 2026, the Ministry of Trade announced that fines for misleading advertisements and unfair commercial practices may range from 99,339 TL to 39,916,524 TL, depending on factors such as the unfairness of the violation, benefit obtained, harm caused, fault, economic condition of the violator, advertising medium and whether the unfair practice occurs nationwide or through advertising.
AI-generated advertisements may spread quickly across social media, websites, video platforms and e-commerce channels. This increases enforcement and reputational risk. Even if an advertisement is later removed, screenshots, downloads and reposts may remain available. Therefore, businesses should review AI-generated content before publication.
Why AI Advertising Compliance Matters
AI advertising compliance is important not only because of administrative fines. It also protects consumer trust, brand reputation and market fairness. Consumers may react strongly when they discover that a human-looking character, testimonial or recommendation was artificial. This may create reputational damage even if the legal sanction is limited.
The Ministry of Trade’s digital advertising research shows that digitalization has increased consumer exposure to online advertisements and that many consumers have difficulty distinguishing advertising content in digital environments. The same research noted that 2023 Advertising Board files were heavily concentrated in digital media and that dark commercial patterns and manipulative digital practices had become significant consumer protection concerns.
AI may intensify these problems because it can make advertisements more realistic, personalized and emotionally persuasive. For this reason, businesses should treat AI advertising as a high-compliance area.
Practical Compliance Checklist for AI-Generated Advertisements
Businesses using AI-generated advertisements in Turkey should apply a strict compliance checklist before publication.
First, identify whether the advertisement uses AI-generated characters, voices, images, testimonials, product visuals or personalized text.
Second, determine whether consumers may believe an AI-generated character is a real human. If so, clear disclosure is required.
Third, check whether the advertisement uses the digital copy of a real person. If it creates the impression that the person personally experienced or recommended the product, the advertisement should not be published.
Fourth, obtain consent where a real person’s image, voice, name, likeness or identity is used.
Fifth, review all claims. AI-generated text should not include unsupported statements such as “clinically proven,” “guaranteed,” “number one,” “doctor recommended” or “risk-free.”
Sixth, verify product visuals. AI-generated images should not exaggerate product performance, size, quality, effect or availability.
Seventh, avoid fake testimonials. AI should not be used to generate artificial consumer reviews or false personal experiences.
Eighth, check sector-specific rules. Healthcare, cosmetics, food supplements, finance and real estate require special review.
Ninth, review targeted advertising and data protection implications. If AI is used to personalize ads, consumers should receive appropriate information about targeting criteria.
Tenth, preserve records. Businesses should keep prompts, drafts, final visuals, approval records, consent documents, substantiation evidence and publication screenshots.
Best Practices for Brands and Agencies
Brands and agencies should establish internal AI advertising policies. These policies should define when AI may be used, which approvals are required, what disclosures must be included, how consent is obtained, how claims are substantiated and how risky content is escalated to legal review.
Marketing teams should not rely solely on AI outputs. AI systems may produce confident but legally inaccurate statements. Every AI-generated claim should be reviewed by humans before publication. High-risk claims should be supported by legal and technical evidence.
Agencies should inform clients when AI is used in campaign production. Contracts between brands and agencies should include clauses on AI use, intellectual property, personality rights, disclosure obligations, compliance with Turkish advertising law, indemnity and removal of unlawful content.
Influencer agreements should also address AI. If an influencer uses AI-generated visuals, voiceovers, filters, avatars or digital enhancements, the brand should know and approve the content. If the influencer’s own digital copy is used, the scope of consent should be clearly regulated.
Conclusion
AI-generated advertisements under Turkish advertising law represent a new and rapidly developing compliance area. Artificial intelligence can make advertising more creative, efficient and personalized, but it can also mislead consumers if used without transparency and legal control.
The 2026 amendments to the Regulation on Commercial Advertising and Unfair Commercial Practices introduced specific rules for AI-generated advertisements. If an advertisement uses artificial intelligence to create digital characters that cannot be distinguished from real humans, this must be clearly, understandably and distinguishably disclosed. In addition, advertisements using the AI-generated digital copy of a real person in a way that creates the impression that the person personally experienced or recommended a product or service are prohibited.
These rules reflect the core principles of Turkish advertising law: truthfulness, transparency, fairness and consumer protection. AI-generated advertisements must not fabricate experience, create false endorsements, exaggerate product results, imitate real persons without proper basis or hide artificial elements that affect consumer perception.
For businesses operating in Turkey or targeting Turkish consumers, AI advertising should be treated as a legal compliance issue, not merely a creative production method. Every AI-generated campaign should be reviewed before publication, especially where it involves human-like characters, digital copies, synthetic voices, testimonials, health claims, children, targeted advertising or sensitive sectors.
A compliant AI advertising strategy should be transparent, evidence-based and respectful of consumer autonomy. In the Turkish market, the safest approach is not to hide the use of artificial intelligence, but to use it openly and responsibly. Brands that adopt this approach can benefit from AI’s creative potential while reducing legal risk, protecting consumer trust and complying with Turkish advertising law.
No Responses