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AI transparency and AI-generated creatives in Criteo Commerce Growth

Regulators in several markets require extra transparency when ads use content that is generated or materially modified with artificial intelligence (AI). This is especially relevant when your Commerce Growth campaigns include:

  • AI-generated or heavily AI-edited product visuals or lifestyle images

  • AI-generated or materially edited video

  • AI-synthesized or cloned voices

  • synthetic or AI-generated people who could be mistaken for real individuals

In some jurisdictions, there are also specific consent and disclosure requirements when you use an AI-generated or digitally replicated likeness, voice, or performance of a person.

This article explains, at a high level, how responsibilities are shared between you and Criteo for Commerce Growth campaigns when AI is involved in creatives.


Who is responsible for what?

A simple way to think about roles:

Tool/model providers

Build AI systems and ensure their outputs can carry technical signals (for example, provenance metadata) so that AI-generated or AI-modified content can be detected. 

You (Advertiser, Agency, Brand, and Retailer)

You are the deployer. You can decide when and how to use AI content in your campaigns, and are responsible for:

  • obtaining any necessary rights and consents, and

  • applying any required visible disclosures or labels for end users under applicable laws and platform policies.

Criteo

Criteo is the advertising platform and service provider here. Criteo supports transparency by:

  • preserving and surfacing AI-related signals where Criteo serves ads, and

  • labelling creatives that Criteo itself generates or materially modifies with AI on the surfaces it controls, in line with applicable requirements.


What is required from you?

When you use AI in creatives that run with Criteo Commerce Growth, we recommend that you:

  1. Identify where AI is used 
    Keep track of creative assets you upload that were generated or materially modified using AI, including:

    • synthetic or AI-generated people

    • AI-generated or heavily AI-edited product visuals and backgrounds

    • AI-modified video

    • AI-synthesized or cloned voices

  1. Secure rights and consent 
    Ensure you have the appropriate rights and consent for any AI-generated likenesses, voices, or performances when a real person’s identity or image is involved.

  1. Apply required disclosures 
    Where your legal team considers it necessary, add clear AI-related disclosures before creatives are used in campaigns. Depending on the market and use case, this might include:

    • labels such as “AI-generated” or “AI-modified”, or

    • disclosures such as “This ad contains a synthetic performer”.

  1. Align with your legal counsel 
    Confirm with your own legal counsel how AI transparency and consent rules apply to:

    • your business and brands

    • your markets

    • your specific creative and catalog workflows


How does Criteo handle creatives in Commerce Growth
?

Criteo has implemented measures to support AI transparency across Commerce Growth workflows.

  • Advertiser-supplied creatives and catalog content

    • For Commerce Growth, Criteo does not create your original product catalog images or standalone creatives in these flows; we ingest the assets you or your partners provide.

    • When your assets carry AI-related disclosures or machine-readable provenance (for example, metadata added by your tools), Criteo's current direction is to preserve and respect these signals in our systems and ad delivery, rather than stripping them.

  • Creatives that Criteo generates or materially edits using AI

    • When Criteo uses its own tools and services to generate or materially modify creatives on your behalf (for example, AI-assisted images, video, or copy produced by our teams or integrated tools), we apply and preserve relevant AI labels on the surfaces we control in line with applicable requirements.

    • We will not knowingly serve creatives that appear to violate AI-related transparency or consent requirements and may pause delivery of non-compliant assets.

  • Ongoing improvements

    Criteo will be evolving its services, and is currently scoping changes that would make it easier to:

    • indicate when a creative is AI-generated or AI-modified (for example through self-declaration in Criteo interfaces and APIs), and

    • use standardized AI-content signals (such as provenance metadata) consistently across campaigns

    These capabilities are not yet available; once rolled out, they are intended to reduce manual effort, improve consistency of AI labelling, and provide a clear, auditable framework for handling AI-related content. We will communicate the details and expected impact to you before these changes go live.