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AI Washing

What is AI washing?

AI washing is marketing or disclosure that overstates, misrepresents or fabricates the role of artificial intelligence in a product — “AI-powered” features that are rules engines or human labour behind the curtain, invented model capabilities, or inflated automation claims. It is not an AI Act concept; the exposure runs through general law: securities and investor-fraud rules (the SEC has brought AI-washing enforcement since 2024), consumer protection and unfair competition (in Türkiye: TKHK and TTK haksız rekabet), and advertising self-regulation.

Where it bites hardest

  • Fundraising: pitch decks and information rights materials are fraud-rule territory — the cheapest claim to make and the most expensive to defend;
  • M&A and investment documents: “AI capabilities” representations and warranties are now standard — an inflated claim becomes an indemnity event at exit;
  • Product marketing: “AI” claims must be substantiated like any performance claim.

Why it matters

The fix is an evidence file: for every public AI claim, keep a one-page substantiation memo (what the model does, metrics, human role). Due diligence teams now ask for exactly this — see our AI due diligence guide.