Philippines - AI Campaign Content Prohibition (11064/2024)

Overview

The Commission on Elections (COMELEC) Resolution No. 11064 represents the Philippines' first comprehensive regulatory framework addressing the intersection of artificial intelligence, social media, and democratic electoral processes. Adopted on September 17, 2024, and effective from September 26, 2024, the resolution specifically governs the 2025 national, local, and BARMM parliamentary elections. The regulation emerged in response to growing global concerns about AI-generated misinformation, deepfakes, and coordinated inauthentic behavior that threaten electoral integrity. By establishing clear rules for AI disclosure, prohibiting manipulative synthetic media, and mandating comprehensive registration of digital campaign platforms, Resolution No. 11064 seeks to preserve public trust in democratic institutions while accommodating legitimate uses of digital technology in political communication. The COMELEC developed this framework through consultations with technology companies, civil society organizations, fact-checking networks, and international election integrity experts, recognizing that the Philippines' high social media penetration rate (over 85% of the population) makes it particularly vulnerable to digital manipulation campaigns. The resolution balances innovation and security by permitting AI use in campaigns while requiring transparency and accountability measures that enable voters to make informed decisions based on authentic information.

Definitions

Resolution No. 11064 establishes precise definitions for key terms governing AI and digital campaign activities. AI-generated content encompasses any text, image, audio, video, or multimedia material created, modified, or manipulated using artificial intelligence, machine learning algorithms, or automated systems, including but not limited to chatbots, automated reply systems, synthetic voice generators, and image manipulation tools. Deepfakes are defined as AI-generated or AI-manipulated audio, visual, or audiovisual content that falsely depicts real persons saying or doing things they did not actually say or do, or that misrepresents events that did not occur, with the intent or likely effect of deceiving viewers about the authenticity of the content. Digital campaign platforms include websites, social media accounts (Facebook, Instagram, Twitter/X, TikTok, YouTube, etc.), mobile applications, email lists, messaging channels, and any other internet-based communication tools used for electoral campaigning. Coordinated inauthentic behavior refers to the use of multiple fake accounts, bots, or automated systems acting in concert to artificially amplify content, create false impressions of public support, or manipulate online discourse. Paid content includes any campaign material for which a content creator, influencer, or platform received monetary compensation, in-kind contributions, or other valuable consideration. The resolution clarifies that campaign materials encompass any communication that promotes or opposes a candidate, party, or political position, regardless of whether it explicitly solicits votes, thereby capturing indirect advocacy and issue-based messaging designed to influence electoral outcomes.

Governance and Institutional Framework

The institutional architecture for implementing Resolution No. 11064 centers on the Commission on Elections (COMELEC), the Philippines' constitutional body responsible for administering all elections and ensuring their integrity. COMELEC possesses broad quasi-judicial and administrative powers to regulate campaign activities, investigate violations, and impose sanctions. For Resolution No. 11064 enforcement, COMELEC established the Task Force Katotohanan, Katapatan, at Katarungan (KKK) sa Halalan (Task Force for Truth, Honesty, and Justice in Elections), a specialized unit with technical expertise in digital media analysis, AI detection, and online investigation. Task Force KKK coordinates with multiple government agencies including the Department of Information and Communications Technology (DICT), which provides technical infrastructure and policy support; the National Telecommunications Commission (NTC), which has authority over telecommunications and internet service providers; and the Cybercrime Investigation and Coordinating Center (CICC), which investigates digital crimes and coordinates law enforcement responses. COMELEC has also formalized partnerships with major social media platforms through memoranda of understanding. These agreements with Meta (Facebook, Instagram), TikTok, Google (YouTube), and Twitter/X establish expedited reporting channels, shared technical protocols for identifying violative content, and procedures for rapid content takedown when violations are confirmed. Additionally, COMELEC collaborates with accredited fact-checking organizations such as Vera Files, Rappler, and Tsek.ph, which monitor campaign content and report suspected violations. Citizen watchdog groups including the Parish Pastoral Council for Responsible Voting (PPCRV) and VoteReportPH contribute to grassroots monitoring and public education about AI-related electoral risks. This multi-stakeholder governance model recognizes that effective enforcement requires technical capacity, legal authority, platform cooperation, and civic engagement working in coordination.

Key Focus Areas

Resolution No. 11064 addresses six primary focus areas in regulating AI and digital campaigns. First, prohibition of deepfakes and manipulated content: The resolution absolutely forbids the creation, distribution, or promotion of AI-generated audio, video, or images that falsely depict candidates making statements they never made, performing actions they never took, or participating in events that never occurred. This prohibition extends to synthetic media that distorts the substance or context of actual statements to create misleading impressions. Second, mandatory AI disclosure: All permitted AI-generated campaign materials must include clear, conspicuous, and persistent labels indicating that artificial intelligence was used in their creation. The disclosure must specify the nature of AI involvement (e.g., "This video uses AI-generated voice synthesis," "This image was created using AI," "This text was generated by an AI chatbot"). Labels must be visible or audible for sufficient duration and cannot be obscured, minimized, or hidden through design choices. Third, comprehensive platform registration: Candidates and political parties must register every digital platform used for campaigning by December 13, 2024, including websites, all social media accounts, email distribution lists, mobile apps, and third-party platforms managed on their behalf. Registration updates are required within 24 hours of creating new campaign accounts. Fourth, paid content transparency: All sponsored content, influencer partnerships, and paid promotions must include clear sponsor identification disclosures. Content creators receiving any form of compensation must register with COMELEC and file periodic reports declaring the source and amount of payments received. These expenditures count toward candidates' official spending limits, ensuring financial accountability. Fifth, prohibition of inauthentic amplification: The use of fake accounts, bots, automated systems, or coordinated networks to artificially inflate engagement metrics, create false impressions of public support, or manipulate trending topics is strictly forbidden. Sixth, candidate accountability: Candidates and parties are held responsible not only for content they directly produce but also for materials created by their official campaign teams, contractors, and in some circumstances, supporters acting on their behalf. This broad accountability framework incentivizes campaigns to actively monitor and control their digital presence and supporter activities.

Implementation Framework

Implementation of Resolution No. 11064 follows a structured multi-phase approach. Phase 1 (September-November 2024): Public Education and Outreach. COMELEC conducted nationwide information campaigns to educate candidates, political parties, digital marketers, content creators, and the general public about the new AI and social media rules. This included webinars, printed guides, video tutorials, and partnerships with media organizations to disseminate information about registration requirements, disclosure obligations, and prohibited activities. Phase 2 (October-December 2024): Registration Period. Digital campaign platform registration opened on October 1, 2024, with the mandatory deadline of December 13, 2024. Candidates and parties submit registration forms through COMELEC's online portal, providing comprehensive lists of all digital platforms, authorized administrators, and third-party service providers. Content creators and influencers register separately and file initial declarations of any existing paid relationships with political campaigns. Phase 3 (December 2024-January 2025): Pre-Campaign Monitoring. Task Force KKK begins active monitoring of registered platforms and conducts baseline assessments of content patterns, identifies potential risks, and coordinates with platform partners to establish technical protocols for rapid response. Phase 4 (February-May 2025): Active Campaign Period Enforcement. During the official campaign period (February 11-May 10, 2025 for national candidates; March 28-May 10, 2025 for local candidates), Task Force KKK operates at full capacity with 24/7 monitoring, rapid investigation of reported violations, issuance of show-cause orders, coordination of content takedowns, and preparation of cases for legal prosecution. The task force maintains a public reporting portal where citizens can submit suspected violations, supported by evidence such as screenshots, videos, or links. Phase 5 (Post-Election): Evaluation and Legal Actions. After the May 12, 2025 election, COMELEC conducts comprehensive review of implementation effectiveness, prosecutes serious violations through the Philippine court system, and develops recommendations for improving the regulatory framework for future elections. Throughout all phases, COMELEC maintains transparency through regular public reports on enforcement statistics, trends in violations, and outcomes of investigations, building public confidence in the electoral integrity framework.

Monitoring and Evaluation

COMELEC employs a sophisticated multi-layered monitoring and evaluation system to detect violations and assess Resolution No. 11064's effectiveness. Technical monitoring utilizes AI detection tools and digital forensics software to identify deepfakes, manipulated media, and coordinated inauthentic behavior. Task Force KKK partners with academic institutions and technology companies to access advanced detection capabilities, including facial recognition analysis, voice pattern authentication, metadata examination, and network behavior analysis to identify bot networks and fake account clusters. Platform collaboration provides real-time alerts when platform partners' own detection systems identify content that potentially violates Philippine election rules. The memoranda of understanding with Meta, TikTok, and YouTube establish formal escalation pathways where platforms can flag suspicious content for COMELEC review, and COMELEC can request expedited takedowns when violations are confirmed. Fact-checking partnerships leverage the expertise of accredited fact-checking organizations that continuously monitor campaign content across all platforms. These organizations apply international fact-checking standards to verify claims, identify manipulated media, and expose coordinated disinformation campaigns, submitting formal reports to Task Force KKK with supporting evidence. Citizen reporting channels enable members of the public to submit violation reports through COMELEC's online portal, mobile app, email hotline, and telephone hotline. Each report receives a tracking number, and complainants receive updates on investigation status and outcomes. Quantitative metrics tracked include number of registered digital platforms, number of violation reports received, response times for investigations, content takedown rates, show-cause orders issued, criminal cases filed, and candidate compliance rates with registration and disclosure requirements. Qualitative assessment examines the nature and sophistication of AI misuse attempts, evolving tactics employed by violators, effectiveness of deterrent measures, public awareness levels, and voter confidence in information authenticity. COMELEC publishes monthly monitoring reports during the campaign period and comprehensive post-election evaluation reports, contributing to institutional learning and regulatory refinement for future electoral cycles.

Penalties, Liability, and Appeals

Resolution No. 11064 establishes a graduated penalty structure reflecting violation severity. Administrative penalties include show-cause orders requiring alleged violators to explain their actions and potentially face sanctions such as mandatory content removal, formal warnings placed on public record, temporary suspension of digital campaign privileges, and monetary fines ranging from PHP 50,000 to PHP 500,000 (approximately USD 900 to USD 9,000) depending on violation nature and scope. Criminal liability arises under the Omnibus Election Code (Batas Pambansa Blg. 881), which provides for imprisonment of one to six years for election-related offenses including the dissemination of false information designed to influence electoral outcomes. Violations involving deepfakes or coordinated disinformation campaigns may also trigger charges under the Cybercrime Prevention Act of 2012 (Republic Act No. 10175), particularly for computer-related identity theft and cyber libel, which carry additional penalties including imprisonment of six to twelve years and substantial fines. Disqualification represents the most severe sanction: candidates found guilty of serious violations may be disqualified from the election, and if already elected, may face removal from office and permanent disqualification from holding public office in the future. Third-party liability extends to content creators, influencers, digital marketing agencies, and platform administrators who knowingly participate in creating or distributing prohibited content, or who fail to comply with registration and disclosure requirements. These parties face both criminal prosecution and civil liability for damages caused by their actions. Candidate accountability operates on a strict liability principle: candidates are presumed responsible for content produced by their official campaign organizations and may be held accountable for supporter activities where evidence indicates tacit approval, failure to disavow, or negligent oversight. The burden shifts to candidates to demonstrate active measures taken to prevent and address violations by their supporters. Appeals process allows parties subject to COMELEC sanctions to file motions for reconsideration within five days of receiving the decision, presenting additional evidence or legal arguments. If the motion is denied, appeals may be elevated to the COMELEC en banc (full commission), and ultimately to the Supreme Court of the Philippines through petitions for certiorari. However, given the compressed timeline of election periods, appeals are subject to expedited procedures, and COMELEC sanctions typically remain in effect pending appeal unless specifically stayed by a court order. This enforcement framework aims to provide meaningful deterrence while preserving due process rights for accused parties.

Relationship to Other Instruments

Resolution No. 11064 operates within a comprehensive legal ecosystem governing elections, data protection, and digital communication in the Philippines. The resolution implements and extends provisions of the Omnibus Election Code (Batas Pambansa Blg. 881), the foundational statute establishing election administration procedures, campaign regulations, and enforcement mechanisms. The Election Code's prohibitions on false information, illegal propaganda, and election-related offenses provide the statutory basis for COMELEC's authority to regulate AI-generated content and impose penalties for violations. The resolution complements the Data Privacy Act of 2012 (Republic Act No. 10173), which governs the processing of personal data and establishes requirements for consent, transparency, and accountability. AI systems used in political campaigns that process personal data for voter targeting, sentiment analysis, or personalized messaging must comply with Data Privacy Act requirements, and the National Privacy Commission's Advisory No. 2024-04 specifically addresses AI systems' data privacy obligations, creating synergies between data protection and electoral integrity frameworks. The resolution also aligns with the Cybercrime Prevention Act of 2012 (Republic Act No. 10175), which criminalizes identity theft, cyber libel, and other computer-related offenses relevant to deepfakes and AI-generated impersonation in political contexts. Resolution No. 11064 references and coordinates with COMELEC Resolution No. 10730 (Fair Election Practices), which establishes general standards for campaign conduct, and COMELEC Resolution No. 10732 (Campaign Finance), which sets spending limits and reporting requirements now extended to include digital advertising expenditures. At the international level, the resolution reflects principles from the European Union Code of Practice on Disinformation and UNESCO's Guidelines for Governance of Digital Platforms, adapting global best practices to the Philippine context. COMELEC coordinates with the ASEAN Regional Framework on Electoral Integrity, sharing experiences and lessons learned with electoral management bodies across Southeast Asia facing similar challenges from AI-enabled manipulation. The resolution also anticipates and complements pending legislation including House Bill No. 7396 (Artificial Intelligence Development and Regulation Act) and House Bill No. 7913 (AI Bill of Rights), which would establish broader national AI governance frameworks. This multi-layered legal architecture ensures that electoral AI regulation is not isolated but integrated into comprehensive digital governance, human rights protection, and democratic accountability systems.

International Alignment

Resolution No. 11064 positions the Philippines as a regional leader in addressing AI-related electoral challenges and demonstrates alignment with emerging international standards for election integrity in the digital age. The resolution incorporates core principles from the International Covenant on Civil and Political Rights (ICCPR), particularly Article 25's guarantee of genuine periodic elections conducted by secret ballot, ensuring free expression of the will of the electors. By prohibiting AI-generated manipulation while protecting legitimate campaign speech, the resolution balances free expression rights (ICCPR Article 19) with the state's obligation to prevent interference with electoral integrity. The framework reflects guidance from the Venice Commission (European Commission for Democracy through Law), which has issued reports on digital technologies' impact on elections and the need for transparent, accountable regulatory approaches that preserve democratic principles while addressing technological risks. COMELEC's approach mirrors elements of the European Union's Code of Practice on Disinformation (2022), particularly the emphasis on platform accountability, transparency in political advertising, and empowerment of fact-checkers and civil society. The resolution aligns with UNESCO's Internet Universality ROAM principles—Rights-based, Open, Accessible to all, and Multi-stakeholder participation—by ensuring that AI regulation respects human rights, maintains an open digital ecosystem, ensures access to authentic information for all voters, and incorporates diverse stakeholders in governance. The multi-stakeholder enforcement model involving government, platforms, civil society, and citizens reflects OECD Principles on AI, particularly the emphasis on transparency, accountability, and stakeholder engagement in AI governance. Resolution No. 11064 contributes to the Christchurch Call to Action's goals of eliminating terrorist and violent extremist content online while protecting freedom of expression, adapted to the electoral context of preventing violence-inciting disinformation. COMELEC actively participates in international networks including the Association of World Election Bodies (A-WEB) and the Global Network of Domestic Election Monitors (GNDEM), sharing Philippines' experiences with AI regulation and learning from comparative experiences in countries like Taiwan, which has implemented similar deepfake disclosure requirements, and the European Union, which is developing comprehensive AI regulatory frameworks under the AI Act. The Philippines' approach has been highlighted by international organizations including the International Foundation for Electoral Systems (IFES) and the International Institute for Democracy and Electoral Assistance (International IDEA) as an innovative model for democracies seeking to adapt electoral regulations to AI-enabled information environments. This international engagement ensures that Philippine electoral AI governance evolves in dialogue with global best practices, contributes to international norm development, and benefits from comparative learning while maintaining contextual appropriateness for Philippine democratic institutions and social media landscape.

Implementation Timeline

Sources and References