The Rule

The Substance Test

Disclose when AI is doing the creative work your listeners came for.

The test is not "was any AI involved?" It's about substance. If AI generated or performed the core content of your episode (the voice, the narration, the conversation), that's substance. If AI helped with production (a jingle, cleanup, show notes), that's a tool.

Apple Podcasts uses the same concept: disclosure is required when AI generates "a material portion of the podcast's audio." The word material is doing the heavy lifting. A 10-second AI-voiced intro before 45 minutes of two human hosts is not material. A fully AI-narrated episode is.


The Decision Test

Ask one question about each episode:

"Is AI doing the creative work my listeners came for?"

If AI is the performer (delivering the content listeners engage with as speech, narration, or conversation): disclose.

If AI is a production tool (supporting human performance with cleanup, music beds, jingles, effects, or behind-the-scenes work): don't disclose.

This mirrors how Apple, the EU AI Act, and the Partnership on AI all define materiality.


What Requires Disclosure

These are cases where AI is doing the substantive creative work:

Use CaseWhy
Fully AI-generated narration
A synthetic voice delivers the episode
AI is the performer. The voice the listener came for is not human. Clearest case.
AI dialogue or conversation
e.g., NotebookLM-style two-host discussions
Both "hosts" are synthetic. AI is doing all the performative work.
AI-translated episodes
Your voice cloned into another language
The entire audio in that language is AI-generated. The substance of that version is synthetic.
AI voice delivering content segments
AI reads listener questions, narrates sections
AI is delivering content the listener engages with as speech. That's substance, not production.
Self-voice cloning + AI-written content
AI wrote the script AND generated the audio
AI is doing the creative work at every level. The ideas aren't yours, the words aren't yours, and the performance is synthetic.
Human voice + fully AI-written script
You recorded yourself reading AI-generated content
AI created the substance your listeners came for. You performed it, but the creative work (ideas, words, narrative) is AI's.

The Voice Cloning Question

Self-voice cloning is the hardest case in this framework. It requires separating two things: the creative substance and the delivery method.

What happenedCreative substanceDisclose?
You wrote the script. AI cloned your voice to narrate it.Yours. Your ideas, your research, your words, your editorial judgment.No
AI is a production method, not the creator.
AI wrote the script. AI cloned your voice to narrate it.AI's. The ideas, words, and performance are all synthetic.Yes
AI is doing the creative work at every level.
You wrote part, AI wrote part. AI cloned your voice.Mixed.Use judgment. If AI generated a material portion of the content, disclose.

Why this distinction matters: When you write your own script and use your cloned voice to deliver it, the creative work your listeners came for (your perspective, your expertise, your personality, your editorial voice) is 100% yours. AI is just the delivery mechanism. This is closer to choosing a microphone than to delegating creative work.

The listener came for your ideas. Whether you spoke those ideas into a microphone, dictated them, or produced them via voice cloning, the substance is the same.

When you should still consider disclosure: Even when the substance is yours, if the cloned voice delivers a full episode and listeners would reasonably assume they're hearing a live recording, transparency is good practice. You don't need the AI tag for this, but a note in your show notes ("This episode was produced using my cloned voice") is a nice touch.


What Does NOT Require Disclosure

These are cases where AI is a production tool, not a performer:

Use CaseWhy
Self-voice cloning + your own contentYour ideas, your words, your voice. AI is the delivery method, not the creator.
Short AI-voiced intro or outro
A produced jingle or bumper
Production element. Not the substance of the episode. The listener came for the human hosts.
AI-generated background music
Ambient beds, theme music
Music supporting human content is a production choice. Like using a stock music library.
AI sound effects
A ding, a whoosh, a transition
Functional audio elements. Same category as stock sound libraries.
Noise removal / audio cleanupProduction tools, not content generators. Every framework exempts this.
Filler-word removal (um, ah)Editing, not generation. Every word the listener hears was spoken by the host.
Audio leveling, EQ, compression, masteringStandard post-production, even when AI-powered.
AI-generated transcriptsDerivative of human-spoken audio. The audio itself is human.
Show notes, titles, descriptions, chaptersText metadata. The listener's audio experience is unchanged.
AI-assisted scriptwriting
Brainstorming, outlining, research, editing suggestions
You wrote the core content. AI helped with the process, not the substance. Apple, YouTube, and Meta all explicitly exempt this.
Research and fact-checkingTool use, not content generation.

Performer vs. tool.

A human host with an AI-generated jingle: AI is a tool. No disclosure.

An AI voice narrating the whole show: AI is the performer. Disclose.

Your own cloned voice reading your own script: your substance, AI delivery. No disclosure.

You recording yourself reading a fully AI-written script: AI created the substance. Disclose.

AI reading listener questions between human segments: AI is delivering content. Disclose.


Worked Examples

Because "substance" can feel subjective, here are concrete scenarios:

ScenarioSubstance?Disclose?
10-sec AI voice intro, then 45 min of 2 human hostsNo. Production element.No
AI narrates the whole episode, human only in intro/outroYes. AI is the performer.Yes
You write a script, your cloned voice delivers the full episodeNo. Your ideas, your words.No
AI writes a script, your cloned voice delivers itYes. AI did the creative work.Yes
You prompt AI to write a full script, then record yourself reading itYes. AI created the content.Yes
AI voice clone translates the full episode to SpanishYes. Entire version is synthetic.Yes
AI reads all listener questions between human segmentsYes. AI delivering content.Yes
AI-composed 30-sec theme music, human hosts throughoutNo. Music bed.No
NotebookLM generates a full AI conversation episodeYes. Both speakers are AI.Yes
Human host, AI-composed score running under entire episodeNo. Music is production.No

Why "Substance," Not "Any AI Audio"

An earlier version of this framework said "any AI-generated audio triggers disclosure." We revised it because that's too strict and misaligns with how every major platform defines the obligation.

  1. Apple says "material portion," not "any portion." A 10-second AI jingle before 45 minutes of human conversation is not material.
  2. The listener test confirms it. Would a listener feel misled upon learning the 10-second intro was AI-voiced? Almost certainly not. Would they feel misled upon learning the entire narration was AI? Yes.
  3. Production elements are tools, not content. An AI-generated music bed is the same category as a stock music track from a library. An AI jingle is the same category as hiring a voice actor for a bumper.
  4. Strict rules punish transparency. If "any AI audio = disclose," creators who use a single AI sound effect get the same label as fully AI-generated shows. That makes the label meaningless.

Why Binary Still Works

Even though the test involves judgment (is this substance?), the disclosure itself remains binary: yes or no.

  1. The explicit tag has been binary for 20 years. Podcasters don't agonize over "how explicit" their episode is. They check the box or they don't. It works because it's simple.
  2. Graduated systems create decision fatigue. "Is my show AI-assisted because I used ChatGPT for research?" That question shouldn't exist.
  3. Machines need binary signals. Directories, apps, and recommendation engines need a flag they can filter on. A boolean is actionable.
  4. Nuance belongs in show notes, not in tags. The tag says "AI is doing substantive creative work in this episode." The show notes say "here's how."
  5. No major platform uses percentage thresholds. Not Apple. Not YouTube. Not Meta. Not the EU AI Act.

The checkbox is not a punishment. It is a signal. Checking it does not mean your content is lesser. It means you're transparent about how your content was made.


Cross-Platform Alignment

This framework was built by studying what every major platform and regulatory body requires:

Platform / FrameworkTheir RuleThis Framework
Apple PodcastsDisclose when AI generates "a material portion of the podcast's audio""Material portion" = substance.
YouTubeDisclose "realistic altered or synthetic content." Exempt: scriptwriting, audio cleanupExempt list matches.
MetaLabel photorealistic AI video/audio. Auto-detect via C2PAAudio substance maps to voice/narration rules.
SpotifyThree tiers: human, AI-assisted, fully AI-generatedSimpler binary, but compatible.
EU AI Act
Article 50, effective Aug 2026
Deepfakes must be disclosed. Fines up to 15M EUR / 3% global turnoverPrepares creators for EU compliance.
FTC (US)Deceptive AI endorsements violate Section 5. $51,744 per violationPrevents deception by defaulting to transparency.
TikTokDisclose realistic AI people/scenes. Auto-labels via C2PAAligned for audio equivalents.
BBCAll generative AI use must be disclosedBBC's rule is stricter (we exempt production tools).
Partnership on AIMaterial = voice/likeness clones. Immaterial = de-noisingSubstance test mirrors their materiality framework.
C2PACryptographic provenance chain in media filesNot yet in podcast audio, but conceptually aligned.

Sources & References

Platform Policies

Regulatory

Industry Frameworks

Podcasting 2.0 Namespace Discussions


About This Framework

Created by Alberto Betella, PhD, co-founder of RSS.com. This framework was built by researching what every major platform and regulatory body requires, then distilling it into a clear, actionable set of rules for podcasters. See Sources & References.

This framework is offered as a public resource for the podcasting community. It is not legal advice. Each platform has its own AI disclosure policies, and those policies may change. Always check the specific requirements of the platforms where you distribute your podcast. By using this framework, you acknowledge it is general guidance and does not replace compliance with individual platform rules or applicable laws.

Try the interactive tool to quickly determine whether your episode needs disclosure.