Compliance

FTC Act Section 5 (AI Enforcement)

Federal authority prohibiting unfair or deceptive AI practices affecting consumers.

Definition

Section 5 of the FTC Act prohibits "unfair or deceptive acts or practices in or affecting commerce." The Federal Trade Commission has increasingly applied this authority to AI systems, establishing that:

  • Deceptive AI: Making false claims about AI capabilities, data practices, or algorithmic fairness violates Section 5
  • Unfair AI: AI systems causing substantial consumer injury that is not reasonably avoidable and not outweighed by benefits are unlawful
  • Discriminatory AI: AI systems producing discriminatory outcomes may constitute unfair practices

The FTC has issued guidance, brought enforcement actions, and proposed rules related to AI. Key areas include: AI-generated content disclosure, algorithmic discrimination, data security for AI systems, and deceptive AI marketing claims.

Sources

  • 15 U.S.C. § 45
  • FTC Enforcement Actions