FTC: actors, dramatizations and scripted AI avatar ads

Per the FTC's Q&A, if a commercial is an obviously fictional dramatization, the actors in it are not giving testimonials. The same page adds that using actors to portray testimonialists is not covered by the rule unless the underlying testimonials were fake or false, but "could be deceptive in violation of the FTC Act."

The Q&A is about actors in a television ad and does not mention AI avatars, so applying it to avatar video is an inference you should check with counsel. The text is from the FTC Q&A page, read 2026-10-01. Sume facts come from the avatar video and avatar docs.

What does the FTC Q&A say about actors?

Two questions on the page cover it: whether using actors to portray testimonialists in a TV ad would violate the rule, and whether actors in a dramatized commercial are giving fake testimonials.

Is a scripted avatar scene a dramatization?

Sume's docs describe an avatar video as a ready avatar turned into "a script-driven talking video." You write the script; the avatar speaks it. That is a scripted performance, which is the shape the Q&A discusses for actors. Whether a viewer would see the scene as obviously fictional depends on how you stage it, and the Q&A's test is the viewer's, not the tool's.

A review quote read by an avatar and presented as a real customer's words is a different case: the page's carve-out depends on the testimonials not being fake or false. Do not script an invented customer experience as if it happened.

What can I build around an avatar to make a scene read as fiction?

Avatars can be created from a text prompt or a reference image, per the docs, and the avatar video route can take a scene reference. Compose takes one still and one video and returns one MP4 with both on screen. Optional inline captions burn into the final MP4, so a plain line such as "Dramatization" can sit in the frame. These are production controls; the docs do not claim any of them satisfy a legal test.

For the disclosure side, see is #ad enough in a video.

What should I check before running the ad?

Ask whether any statement in the script claims a real customer result, whether the avatar resembles a real person, and whether a viewer would take the clip as a documentary-style testimonial. If yes to any, change the script or add clear on-screen wording, and take advice.