A useful campaign AI policy does four things: names who is accountable, records which tools and uses are approved, sets review gates based on risk, and explains how to handle data, disclosures, and incidents. Start with an inventory, then have election-law and privacy counsel check the policy for the places and channels where the campaign operates. No single set of AI rules applies to every campaign.
What should a campaign AI policy cover?
Write a working policy for the people who make campaign decisions, not just a statement of principle. It should tell staff, volunteers, contractors, and vendors which AI uses are allowed, what needs approval, what data may be entered, and what to do when a tool produces a mistake or suspected disinformation.
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Use the NIST AI Risk Management Framework as a voluntary organizing model: Govern responsibilities and rules; Map the system and its context; Measure relevant risks; and Manage them over time. NIST says risk management should be continuous across an AI system’s lifecycle. The framework is not a legal safe harbor or certification, and NIST says revision is underway.
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Name a policy owner who can maintain the approved-tool list and resolve routine questions. Name a deputy who can handle time-sensitive decisions when the owner is unavailable. Define which campaign entities, staff, volunteers, vendors, accounts, devices, and communications the policy covers. Include a plain-language definition of AI broad enough to cover generative text, image, audio, and video systems, as well as analytics or automated decision tools the campaign may use.
Record the jurisdictions and election contexts in which the campaign operates. Legal duties may turn on the campaign’s location, committee status, the content, its audience, the medium, and who paid for it. A policy should identify who will obtain local election-law and privacy review before approval, and who will re-check requirements when those circumstances change.
Build an inventory before approving use
Keep a register for every campaign AI tool or materially different use. A single service may need multiple entries if, for example, it is used both to transcribe internal meetings and to generate public-facing video. Record:
- Tool or vendor, responsible user, campaign purpose, and date of approval.
- What information is entered, including whether it contains voter, donor, employee, confidential strategy, or other personal data.
- Audience and channel, such as internal staff, a public website, social media, or direct voter communications.
- What the tool produces, who checks it, and who gives final approval.
- Relevant vendor terms, data-use and storage settings, retention period, and deletion process.
- Any required disclosure, limits on use, or incident-reporting instructions.
Useful inventory categories include drafting, translation, transcription, design, image/audio/video generation, voter-facing chat, analytics and targeting, fundraising, and internal operations. These are practical categories for organizing a campaign’s register, not a legal classification.
How should approval work?
Set review gates according to the consequences of the use, rather than treating every AI-assisted task as equally risky. The levels below are a policy design, not a universal legal rule. A campaign can adapt them to its size, election calendar, jurisdictions, and risk tolerance.
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Routine internal assistance
Allow lower-risk tasks such as formatting, brainstorming, or summarizing non-confidential material when a staff member checks the result before relying on it. Keep these uses within approved services and data boundaries. Even routine assistance should not turn an AI-generated answer into an unchecked factual assertion or campaign decision.
Public factual communications
Require a named staff member to verify factual claims in public communications, including names, dates, statistics, quotations, and links to underlying sources. A manager or communications lead should approve publication. For claims about an opponent, voting, or election administration, require a higher level of review because an inaccurate or misleading statement can cause serious harm.
High-impact or synthetic uses
Require senior communications and compliance approval—and legal review where appropriate—before using AI for voter-facing chat, targeting, synthetic depictions or voices of real people, claims about opponents, or information about voting procedures. Set a default rule that no one may publish or distribute fabricated endorsements, impersonations, knowingly false voting details, or deceptive synthetic material on the campaign’s behalf. These prohibitions are prudent policy choices; applicable law may impose additional or different requirements.
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Make the human review specific
Before publication or another consequential use, the assigned reviewer should check:
- Whether factual statements match reliable source material and whether names, dates, and context are correct.
- Whether the campaign has permission to use any image, voice, recording, or other source material.
- Whether the output could unfairly target or misrepresent a person or group.
- Whether a disclosure is required or appropriate, and whether the medium or platform has its own rules.
- Whether the output is suitable for its intended audience and channel.
Keep the source material and final approved version, along with the approver and approval date. Human review does not transfer accountability to the tool’s vendor; the campaign remains responsible for its own publication decisions.
What rules apply to AI-generated campaign ads?
There is no universal answer. Requirements depend on jurisdiction, election type, campaign or committee status, medium, sponsor, and content. An AI-specific campaign-ad rule is not the only possible source of regulation: existing election, advertising, privacy, and platform rules may still apply to AI-assisted material.
United States
For U.S. federal campaigns, the Federal Election Commission’s September 2024 interpretive-rule summary said the federal fraudulent-misrepresentation statute and implementing regulation are technology neutral and can apply to AI-assisted media. The Commission chose not to open a separate rulemaking on AI campaign ads. Its summary put the point this way: “The statute, and the Commission’s implementing regulation, is technology neutral.” This describes the federal framework; it does not resolve state or local rules, every factual scenario, or the legality of a particular ad.
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European Union
The EU has distinct rules for political advertising and AI transparency; one should not be treated as a substitute for the other. The European Commission’s Article 50 guidance says transparency obligations apply from August 2, 2026, including notice obligations for deepfakes and certain public-interest text generated without human review or editorial control. Whether a specific campaign item falls within an obligation depends on the applicable rules and facts. Have EU counsel assess the content, medium, human involvement, and any political-advertising or targeting requirements.
India
In May 2024, India’s Election Commission directed political parties and representatives to refrain from circulating deepfake audio or video and patently false or misleading information. For covered parties, the direction called for specified content to be removed promptly and within three hours of notice. This is a jurisdiction-specific direction for its covered recipients; it is not a deadline for campaigns elsewhere.
Do not equate platform labels with legal compliance
Make a disclosure checklist for each jurisdiction and publication channel. Check who is sponsoring the communication, whether a real person or event has been altered, what kind of synthetic content is involved, and what the law and platform require. A platform label may not meet a legal disclosure duty, and a legally sufficient disclaimer may not satisfy a platform’s separate policy.
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How should a campaign protect data and accounts?
Set an explicit data boundary: staff may use only approved services for campaign work, and must not enter voter, donor, employee, or confidential strategy data into an unapproved AI service. Before approving a vendor, check how it uses, stores, shares, and deletes submitted data, and whether its settings meet the campaign’s requirements. Record the decision in the tool inventory.
Require official devices and communications for campaign work, access controls, strong passwords, and two-step verification. Train users to recognize the approved account and service rather than putting campaign material into a personal account or an unknown online tool. UK government election-security guidance recommends official devices and communications, strong passwords, two-step verification, and learning how to report content on relevant platforms.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What should the campaign do if it finds a suspected deepfake?
Decide in advance who receives reports and who may speak for the campaign. UK government guidance cautions: “Think before you respond to any reports of disinformation.” A rapid public repost or quotation can give false content a larger audience, so do not improvise a response on a personal or campaign account.
- Preserve evidence. Save the URL, time found, screenshots or other available evidence, and relevant context. Avoid altering the original evidence.
- Assess urgency. Determine whether the item falsely depicts a person, could cause immediate harm, or contains incorrect voting information. Escalate urgent voting-related claims promptly to the designated communications and legal leads.
- Notify the designated leads. Send the evidence to the campaign’s named communications and compliance contacts, and to legal counsel when appropriate. Do not let multiple staffers issue uncoordinated responses.
- Report through the appropriate channels. Use the platform’s reporting process and notify the party or other relevant organization where applicable. Keep a record of the report and any platform response.
- Respond only if needed. If a correction or warning is necessary, use official campaign channels and keep it factual. Avoid embedding, reposting, or quoting the suspected false content if doing so would spread it further.
- Log the outcome. Record decisions, reports, corrections, and follow-up actions so the campaign can review what happened and improve its procedures.
How should a campaign choose its approval and disclosure posture?
Policy choices involve trade-offs. A fast approval path can help a small team work efficiently, while a broad pre-approval rule may reduce the risk of an unreviewed public error. The right balance depends on the campaign’s capacity, the use, and the consequences of getting it wrong.
| Policy choice | Lighter-touch approach | More controlled approach | Trade-off to consider |
|---|---|---|---|
| Approval burden | Permit reviewed, low-risk internal uses without advance sign-off. | Require pre-approval for a broader range of AI-assisted work. | Routine work can move faster with delegated review; broader gates may provide more consistency but add delay. |
| Disclosure posture | Use disclosures when required by applicable law or platform rules. | Adopt a broader voluntary disclosure standard where appropriate. | Check legal and platform duties either way; consider transparency, audience trust, and the risk that an unlabeled synthetic item could mislead. |
| Data boundary | Use only approved tools with known data terms and settings. | Restrict use further to services with defined enterprise controls or campaign-managed accounts. | Compare confidentiality, retention, access, and operational cost; do not assume a public service will keep submitted information private. |
| Incident response | Centralize public statements with communications and legal leads. | Delegate limited response authority to trained local staff under a written protocol. | Central control can keep messaging consistent; delegation may improve speed but requires clear limits and training. |
How should the policy stay current?
Train staff, volunteers, contractors, and relevant vendors on approved services, prohibited data, review gates, disclosure checks, and incident reporting. Log approvals, exceptions, disclosures, complaints, incidents, and corrections. Choose a review interval that fits the campaign’s election calendar; NIST does not prescribe a campaign-specific interval.
Reopen the review when the campaign changes a tool or vendor, introduces a new use, enters a different jurisdiction or channel, or encounters a new legal or platform requirement. NIST’s framework emphasizes documented roles, an AI-system inventory, and periodic review, but it does not replace local legal analysis.
Before putting the policy into operation, have local election-law and privacy counsel check its scope, disclosures, data practices, and escalation procedure against the campaign’s actual organization and uses. The U.S. Election Assistance Commission’s AI resources are aimed at election officials and election administration; they do not establish campaign policy requirements.
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