Why did you target me?
Trace the audience data to its supplier, applicable permission and actual use. Personal data is in scope when it supports an advertising decision.
Developing work · IAE Governance Lab · IEEE SA knowledge partnership
From intention to evidence: connect what an AI ad agent was authorized to do, what people were told and what actually happened.
I’m Jay Mandel. I work with Sean Meier on Technical Conformance, Layer 4 of the developing AI Advertising Trust Stack. This page shares our contribution, examples, progress, and the questions still open.
Apply the thinking to your business
My independent Trust Stack consulting service helps you trace a customer problem across promises, people, workflows, technology, and ownership. Start with a focused diagnostic, then scope the work to put the fixes into practice.
Explore the consulting service ↗The consulting service does not confer IAE or IEEE certification or endorsement. The workstream and its proposed technical capabilities remain under development.
Summit I to Layer 4
The IAE Summit I report of 22 April 2026 describes agents that can change their methods while pursuing a goal. Its concerns include consumer choice, meaningful human intervention and responsibility that remains with people and companies.
An AI ad agent is software that creates ads, selects audiences or spends budget. Layer 4’s proposed mandate is to preserve evidence so actual behavior can be checked against authorized intent, permissions and disclosures.
Trace the audience data to its supplier, applicable permission and actual use. Personal data is in scope when it supports an advertising decision.
Compare changes in content or agent behavior with the approved task and limits. Retain human check-ins and interventions.
Record the responsible owner and the authority behind approval. Presence alone does not establish control.
Layer 4 supplies evidence. Other layers define the requirements and response. These examples do not make every use of personal data subject to the same legal consent requirement. See the report and workstream inputs in the source register ↗.
Why appearances are insufficient: 32% mistook human-created content for AI-generated content in the Zefr + OM Media Trials study in the US and Canada. Read the study announcement ↗.
Why companies would adopt it
81% of US adults said they were concerned about how companies use their data in Pew’s 2023 survey. Give people a record they can inspect and a way to challenge misuse.
Serious GDPR violations can bring fines up to €20 million or 4% of total annual global turnover, whichever is higher. Regulators can also restrict or ban processing.
The Dutch regulator announced a €30.5 million fine against Clearview AI in September 2024 for illegal collection for facial recognition. Publicly accessible images do not remove privacy obligations.
Scraping is not automatically illegal. The data, legal basis, rights, purpose and jurisdiction determine the obligations. Survey concern does not prove that people will click a seal or that this proposal will increase sales; adoption and consumer use need testing.
AI company evidence directory / interactive proposal
A LUMAscape groups companies by their role in advertising. Our proposed version links each company to requirements, evidence and a scoped review result. Search a fictional advertiser, agency, data provider, AI tool or adtech partner.
Check sources, permission and what happened.
Connect decisions, changes and handoffs.
Open the records within each review’s scope.
Follow evidence across agencies, tools and platforms.
Compare coverage, evidence gaps and corrections.
The same five fields connect each level: source, permitted use, responsibility, changes and verification. A passing record cannot certify an entire company.
Missing evidence means an unresolved assessment, not verified noncompliance. Every confirmed mismatch must point to the requirement and evidence behind it.
Fictional Advertiser / ORCHARD
The submitted evidence supports the stated use of this ad version. Other ads and company activities are outside this review.
Illustrative record and seal
Ad example / AI assisted
Replace the background; use the performer in US social ads through 31 Mar 2027.
Version 3 replaces the background. The performer’s face and voice are unchanged.
The seal opens the record, including its scope and review date. The symbol alone proves nothing.
Connected evidence / OG-003
Proposed next step: Continue the assessed use. Recheck when the asset, permission or approved task changes.
Public view: requirement, decision, scope, version and review status. Authorized audit access: private identity and supporting evidence. People can challenge the record; the response is recorded.
The evidence we already expect

Beef can combine many inputs. An AI ad can combine a real photo, a synthetic voice, and licensed work. The ingredients need a history.
cyclonebill / Wikimedia Commons · source · CC BY-SA 2.0 · displayed at smaller size.

The certificate records an inspection, its date, and validity. An ad receipt should make approval and authority equally easy to inspect.
NWRGeek / Wikimedia Commons · source · CC0 · historical 2012–2013 certificate.

Mined or lab-grown? What supports the origin and quality claims? Appearance alone cannot answer the questions behind a purchase.
Public-domain diamond photograph · Rawpixel / CC0 source.

A digital card needs evidence of its issuer and ownership. A screenshot alone does not establish either.
NBA Collect by Topps · official product source · illustrative reference, not a claim of ownership.
Art and used cars make the same point: a convincing Picasso needs evidence, and “one careful owner” invites a request for service history. These analogies explain why we ask for records; they do not guarantee truth or safety.
The whole effort
The Institute for Advertising Ethics Governance Lab identifies emerging risks and develops practical standards for accountable advertising, with IEEE Standards Association identified as a knowledge partner. The developing AI Advertising Trust Stack brings governance, technical evidence, and accountability into the same conversation.
Our Layer 4 contribution defines the checkable evidence needed across the data, content and decision lifecycle. It does not replace the other workstreams or speak on behalf of IAE or IEEE. The broader effort needs advertisers, creators, technologists, platforms, auditors, and people affected by advertising to help define what justified trust requires.
Establish purpose and boundaries before testing the system’s behavior.
Set approvals, operating limits, required check-ins and escalation.
Preserve sources, permitted use, responsibility, changes and repeatable verification.
Layers 5 and 6 use the evidence for accountability and ongoing assurance. Layer 2 addresses the workforce. This page focuses on the evidence handoffs rather than defining every workstream.
These are the adjacent workstreams relevant to this example, not a complete specification of the entire Trust Stack. Read IAE’s official Governance Lab overview ↗.
Progress update · 11 October 2026
This is developing work, not an adopted IEEE standard, certification scheme, or completed end-to-end system.
Prepared for The Intention Advantage at Omnicom on 12 October 2026. The current presentation incorporates the Summit I report, defines the ad-agent and data scope, and distinguishes signed Content Credentials from watermarks. The committee still needs to agree the evidence requirements and test them in a real workflow.
Progress updates on this page are dated and added as the work develops. No automated reporting or mailing-list subscription is implied.
Layer 4 · five questions
| Question | What the evidence should show | How someone uses it |
|---|---|---|
| Where did it come from? | Audience-data supplier, creator, tools, AI use, source records and gaps. | Check origin, credit, and ownership claims. |
| What can it be used for? | Applicable permission or license, purpose, region, limits, expiry and withdrawal. | Test a disputed use against permission. |
| Who is responsible? | Responsible company, human or automated decision, approval authority and ability to reject or stop. | Find who controlled the step and hear their response. |
| What changed? | Content edits, changes in agent methods, versions and intervention history. | Compare later actions or versions with their approved purpose and limits. |
| How can it be checked? | Signatures where available, repeatable checks, action logs and protected identity evidence. | Audit without publishing private identities. |
Provenance records origin and changes. A valid record still needs to be checked against the applicable requirements. Human presence must come with authority and the power to reject or stop; private identity evidence stays under controlled access.
Small mark · deeper evidence
Illustrative placements: the mark opens the record for review. These examples do not carry verified approval.

Example Ad / AI assisted

Illustrative frame / AI assisted
The source and edits.
The permission to use it.
The person or company responsible.
Illustrative article / AI assisted
Our everyday examples start with diamonds, digital trading cards, art, used cars, beef and elevator certificates. We already ask for origin, permission, history, and inspection evidence elsewhere. Why should data or AI be different?
Contributions and boundaries
Narrative, permission and accountability questions, stakeholder use, and the connection between evidence and decisions.
Layer 4 technical collaboration: source collection, detection signals, privacy-preserving approval checks, and record carriage.
Compare authorized purpose, permissions and disclosures with actual behavior. Preserve the evidence that workflow and accountability owners need to investigate and correct a mismatch.
C2PA Content Credentials provide signed content-history records. Watermarks are embedded signals that may help recover those records; AI-detection results are estimates. These components do not establish permission or legal compliance on their own. The full evidence record and its governance remain proposals. ChatGPT assisted with this page, deck, and prototype implementation. The source register distinguishes actual production facts, attributed discussion, research references, and fictional examples.
Read the contributor and source table ↗Proposal for discussion
A LUMAscape groups advertising companies by role. Our proposed evidence map connects brands, agencies, data providers, AI tools and adtech partners to a requirement, its supporting records, reviewer, scope, date and result. People and rights holders can inspect the public record and challenge disputed use.
The proposal is to value checkable evidence in purchasing, distribution, and risk review. That is not a promise of lower insurance premiums, guaranteed reach, or an existing certification.
Explore the ecosystem and incentives ↗Follow the AI Advertising Trust Stack work.
What proof is sufficient for the risk? Who verifies it and retains it? Who answers when the evidence stops at a company handoff?