Artificial Intelligence Compliance Plan

Applies To

Overview

Published in October 2024, the FTC Artificial Intelligence Compliance Plan formalizes the agency's internal framework for responsible AI use and signals the standards it expects of regulated entities. The plan addresses transparency in AI-driven decisions, accountability structures for AI oversight, and the principle that AI deployment should deliver measurable public benefit. It situates the FTC's AI governance within existing statutory authority, including Section 5 of the FTC Act prohibiting unfair or deceptive acts or practices. While the plan is primarily descriptive of internal agency governance, it functions as a quasi-binding signal for enterprises by establishing the criteria the FTC applies when evaluating AI-related conduct during investigations. Organizations in sectors the FTC actively monitors, including financial services, health technology, and advertising, face heightened scrutiny under this framework. The plan supplements but does not replace prior FTC guidance on AI, algorithmic fairness, and data practices.

Key Requirements

• •Maintain transparency in AI-driven consumer-facing decisions, including disclosure of material AI involvement in outcomes affecting consumers.
• •Establish internal accountability structures that assign responsibility for AI governance and risk oversight.
• •Document AI use cases, associated risks, and the public benefit rationale for deployment in regulated products or services.
• •Ensure AI systems do not produce outputs that constitute unfair or deceptive acts under Section 5 of the FTC Act.
• •Implement risk management processes proportionate to the potential consumer harm posed by each AI application.
• •Retain records sufficient to demonstrate compliance if subject to FTC inquiry or investigation.

What Your Organization Must Do

• →Audit all AI systems used in consumer-facing products or services and document the purpose, risk profile, and benefit rationale for each.
• →Assign named accountability for AI governance within the compliance function, ensuring clear escalation paths for AI-related risks.
• →Review consumer disclosures to confirm they accurately reflect the role of AI in decisions that materially affect customers.
• →Update internal AI risk management policies to align with the transparency and accountability standards the FTC has articulated in this plan.
• →Brief legal and compliance teams on the plan's signals so that FTC investigation responses and pre-investigation remediation reflect the agency's current expectations.
• →Assess vendor and partner AI tools against the same transparency and accountability standards applied to internally developed systems.