Hello, this is Cheongchul Law Firm.

More and more companies are using AI models or generative-AI virtual experts — so-called virtual influencers — in their advertising. With the amended Guidelines on Endorsements and Testimonials in Labeling and Advertising from the Korea Fair Trade Commission (KFTC) taking effect on June 1, 2026, exactly where and how AI virtual influencers must be disclosed has become much more concrete. Below are the 3 disclosure rules to check in practice, plus the cases where an ad can still be unfair advertising even after proper disclosure.

[Table of Contents]

1. ① Text posts — disclose at the start of the title or first line of the body

2. ② Photos and videos — label next to the figure in a contrasting color

3. ③ User testimonials — must match actual experience results

4. When it is still unfair advertising, and KFTC monitoring

5. How Cheongchul Law Firm can help

① Text posts — disclose at the start of the title or first line of the body

For text-based posts such as blogs and online cafes, you must notify consumers that a virtual figure is included in one of two ways:

• add [Includes Virtual Figure] at the very start of the title, or

• state in the first line of the body: "This post includes an AI-generated virtual figure."

The key is that consumers must be able to recognize, before or immediately upon reading, that the figure is not a real person but an AI-generated virtual one. A small note buried in the middle or at the very end of the text is unlikely to satisfy the disclosure obligation.

② Photos and videos — label next to the figure in a contrasting color

Photo and video ads face stricter requirements than text posts. For the entire time the virtual figure appears, the caption "Virtual Figure" must be displayed right next to the figure.

The caption must be in a color that contrasts with the background. Using a color that blends into the background, or showing the label only briefly during part of the video, is unlikely to be accepted as adequate disclosure. A consumer pausing at any moment of the video should be able to tell that the figure is virtual.

③ User testimonials — must match actual experience results

The third rule concerns not the placement of the label but the truthfulness of the content. If you have a virtual figure deliver a usage experience or testimonial such as "It worked great for me" or "I saw real results," that content must match the actual demonstration or experience results.

The fact that a virtual figure rather than a real person appears does not exempt the testimonial from the truthfulness requirement. Even if the words come from an AI-created figure, a testimonial that differs from the real effect of the product or service may be deemed a misleading representation.

When it is still unfair advertising, and KFTC monitoring

The most important point is that even proper virtual-figure disclosure is not enough on its own. Even if you meet the disclosure obligation, an ad whose content is false or exaggerated may constitute unfair advertising under the Act on Fair Labeling and Advertising.

In other words, an ad using an AI virtual influencer must satisfy both the duty to disclose that the figure is virtual and the duty for the ad content to be truthful. The KFTC has announced it will conduct monitoring so that ads failing to disclose AI virtual figures as required are corrected, making advance review all the more critical for advertisers.

How Cheongchul Law Firm can help

Marketing using AI influencers and virtual figures is spreading quickly, but failing to follow the disclosure rules and testimonial-truthfulness requirements can lead to sanctions under labeling and advertising law. Drawing on hands-on experience in fair trade and AI/emerging-business matters, Cheongchul Law Firm reviews whether a company's advertising complies with the amended guidelines and helps design a compliance framework.

If you have questions about how to disclose AI virtual influencers or about the KFTC endorsement and testimonial guidelines, please feel free to contact Cheongchul Law Firm at any time.

This post is provided for general legal information purposes and does not constitute legal advice on any specific matter. For individual cases, please be sure to consult an attorney.