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Campaign Finance Board backs AI‑content disclosure but warns Intro 12A is too broad and resource‑intensive
Summary
The Campaign Finance Board told the Council it supports a disclosure approach for AI‑generated political content (Intro 12A) but urged narrowing coverage to materially synthetic audio/video and warned of high implementation costs, likely vendor needs and at least a one‑year rollout if enacted.
The Campaign Finance Board’s executive director, Paul Sheamus Ryan, told the committee that Intro 12A’s shift from prohibition to disclosure and naming the CFB as the recipient of provenance information reduces the bill’s legal vulnerabilities, but the agency urged narrowing the law’s scope and realistic resourcing.
"The CFB is well qualified to administer and enforce the requirements of Intro 12A," Ryan said, while cautioning that the board would need significant time and funding to build the technical systems and expertise required. First Deputy Executive Director Amanda Melillo told the room that the agency expects to need outside vendor support and acknowledged there is no reliable off‑the‑shelf detector for modern deepfakes; she said the agency would therefore have to rely largely on proactive disclosure, public complaints, and building internal expertise.
CFB analysts suggested the Council adopt a narrower definition like the Federal AI Transparency in Elections Act — for example, applying disclosure only to images, audio or video substantially generated by AI and exempting minor cosmetic edits or routine use of generative text tools for fundraising emails. They warned that, as drafted, Intro 12A could capture routine campaign uses of generative text or minor design edits and flood the public disclosure database with largely immaterial entries.
CFB staff also flagged implementation realities: Paul Ryan estimated at least a year would be needed after passage to build the necessary internal systems and public database; Amanda Melillo said outside technical expertise would be required and that skilled staff are expensive. The board noted the statute’s current enforcement cap ($10,000 per violation under the Campaign Finance Act) may prove small relative to large independent expenditures and recommended the Council review enforcement remedies.
The committee took testimony and questions but did not record a final vote. Council members followed up on CFB’s staffing and vendor recommendations, and witnesses urged the Council to refine definitions to reduce overbreadth and protect First Amendment interests while providing practical disclosure for materially deceptive synthetic media.
