Beyond the Algorithm: A Guide to COMELEC’s AI Disclosure Rules for 2028

Geraldine Torres-Brillantes

Navigating Resolution 11064: The 2028 Candidate’s AI Compliance Checklist

COMELEC AI disclosure requirements 2028

In 2026, navigating COMELEC’s AI Disclosure Rules for 2028 is a non-negotiable for anyone running a campaign in the Philippines. Under COMELEC Resolution No. 11064 (and its subsequent 2026 updates for the BSKE), the Commission has moved from “suggesting” transparency to “enforcing” it through the Task Force KKK sa Halalan (Katotohanan, Katapatan, at Katarungan).

If you are using AI for your 2028 positioning or the 2026 Barangay elections, here is the compliance framework you must follow:

1. Mandatory AI Disclosures: Watermarks and Audio Spoken Labels

Any campaign material—whether a high-budget video or a simple social media card—that uses AI technology must include a clear disclaimer.

Visual Disclosures: Must be “clear, conspicuous, and not easily removed.” This usually means a permanent watermark or text overlay that stays on screen for the duration of the content.
Audio Disclosures: For synthetic audio (voice clones), a spoken disclaimer must be included at the beginning and end of the clip (e.g., “This audio was generated using AI technology”).
Detailed Context: You must specify the nature of the AI’s involvement (e.g., whether a face was swapped, a voice was cloned, or the background was modified).

2. Consent and Provenance

Prior Consent: You cannot use AI to depict an individual (real or deceased) without documented prior consent.
Watermarking: COMELEC now mandates the use of digital watermarks or cryptographic metadata to ensure the authenticity and provenance of the digital content. This allows the Task Force to trace the “legitimate source” of the material.

3. Registration of Digital Platforms

Before you even post AI content, your platforms must be registered.

Who must register: Candidates, political parties, and even third-party influencers/entities managing pages that primarily promote or oppose a candidate.
What to register: All official social media accounts, websites, blogs, vlogs, and podcasts.
The Deadline: For the 2026 BSKE, registration typically opens shortly after the filing of Certificates of Candidacy (COC).

4. Prohibited Acts & Penalties

The COMELEC is specifically hunting for “malicious use” intended to deceive voters.

Deepfakes & Cheapfakes: Creating media that makes a candidate appear to say or do something they didn’t is a major election offense.
False Amplifiers: Using bots or “fake accounts” to spread AI-generated disinformation.
Penalties: Violation of these guidelines constitutes an election offense under the Omnibus Election Code (OEC).
- Imprisonment: 1 to 6 years (not subject to probation).
- Disqualification: Permanent disqualification from holding public office.
- Takedowns: COMELEC has direct “review channels” with Meta, TikTok, and YouTube to expedite the removal of undeclared or harmful AI content.

In the fifth edition of Winning Strategies for AI Interconnected Elections, Geraldine Torres-Brillantes outlines a ‘Transparency First’ model that turns legal compliance into a trust-building asset. Disclosure isn’t just a legal hurdle—it’s a trust signal to Gen Z voters who value authenticity.

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