Risk · R-118 · Conduct & Customer Outcomes
Misleading AI-generated communications
Customer communications or promotions written by AI are unclear, inaccurate or unbalanced, or leave out information the customer needs or the rules require.
- Severity
- High
- Audience
- Heads-of · Practitioner
- Frameworks
- Article 50 · PRIN 2A.5 · Confabulation
- Responsible AI domain
- Lifecycle stage
- Reviewed
- 2026-11-11
What it is
Organisations now use generative models to write letters, emails, product descriptions, marketing and chat replies. Communications to customers have to be fair, clear and not misleading, and in regulated sectors particular content is required: risk warnings, key terms, the right to complain. A model produces fluent, confident text that may state a feature the product lacks, omit a condition, or stress benefits over risks. Each instance is small. The model writes thousands. The general accuracy problem is covered in misinformation and confabulation; this entry concerns the conduct consequence.
How it happens
- Text is generated from a prompt and sent without review.
- The model is asked to make copy more persuasive.
- Required wording is dropped when content is shortened or personalised.
- Product terms changed and the source the model draws on did not.
Why it matters
A customer who relies on a misleading statement may hold the organisation to it or claim redress. In financial promotion the rules are strict, including on who may approve the content. Personalisation makes the problem harder to see, since no two customers receive the same text.
Warning signs
- Generated communications are not sampled against content standards.
- Marketing prompts ask for urgency or persuasion.
- Complaints quote statements the organisation cannot find in its templates.
- Mandatory wording is missing from some outputs.
Who owns it
The owner of the communication, usually marketing or operations, is accountable. Compliance sets and tests content standards. Whoever approves financial promotions approves those written by AI.
In practice
A savings provider uses a model to personalise renewal emails. For some customers the model describes a rate as guaranteed when it is variable. The same pattern generalises to any customer communication produced faster than it can be read by someone who knows the rules.
Mitigating controls
Primary controls
- Review of AI-generated communications Preventive
- Checks generated communications against content standards before use. Customer communications produced by AI are checked against content standards before use, in full or by sampling according to risk, and required wording is enforced.
Supporting controls
- Evaluation suite and regression testing Detective
- Tests generation against required disclosures. A maintained set of test cases with expected results is run on every change to model, prompt, data or tools, and the results are compared with the approved baseline.
- Factuality and hallucination verification Detective
- Verifies factual claims. Claims, figures and citations in AI-generated output are checked against a trusted source before the output is relied on for a consequential decision or sent to a customer.
Framework and clause references
| Framework | Clause | Title |
|---|---|---|
| EU AI Act | Article 50 | Transparency and disclosure obligations Disclosure of generated content. |
| FCA Consumer Duty (PRIN 2A) | PRIN 2A.5 | Consumer understanding outcome The consumer understanding outcome. |
| NIST Generative AI Profile (NIST AI 600-1) | Confabulation | Confabulation Inaccurate generated text. |
Sources
- EU AI Act: Regulation (EU) 2024/1689 European Union (EUR-Lex) · official text
- NIST Generative AI Profile NIST · framework
Related terms
How to cite
Axiom Verity (2026). Misleading AI-generated communications. Reference Library, R-118. https://axiom-verity.com/risks/misleading-ai-generated-communications. Reviewed 2026-11-11.
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