Aipedia: Charities and trustees

AI images and copy in fundraising appeals

Aipedia, by the Apex broking team · Last reviewed 2026-10-30

Charities can use AI-generated images, copy and voices in appeals, but the Fundraising Regulator expects more transparency the greater the risk of misleading donors. An appeal that donors take as real when it is not is a Code complaint and a reputational risk.

Part of: AI in Charities and trustees

In short

Charities use AI to create appeal imagery, composite case studies, voiceovers and personalised copy. The Fundraising Regulator's AI guidance says the greater the risk of misleading donors, the more transparent you should be, and that AI sound, video and images that could be mistaken for real people or situations should be covered by that transparency. Existing Code standards apply to AI-enabled fundraising. The Charity Commission flags reputational risk from misuse of AI content. Insurance has limits here: regulatory penalties cannot be indemnified under Charities Act 2011 s.189, and reputational harm is not usually an insured loss.

How charities use AI in appeals

AI tools now produce material that once needed a photographer, a studio and a copywriter. Charities use them to:

generate images of beneficiaries, settings or crises where real photography is unavailable or would identify people;
write composite case studies built from several real stories;
create synthetic voiceovers or video presenters;
personalise appeal copy and subject lines at scale.

There are good reasons for some of this, such as protecting a vulnerable beneficiary's identity. The risk lies in donors believing they are seeing a real person or a real event.

The duties that apply

The Fundraising Regulator's AI guidance (updated 8 December 2025): the greater the risk of misleading donors, "the more transparent you should be". AI-generated sound, video and images that could be mistaken for real people or situations should be covered by that transparency.
Charities are accountable for all AI-generated output, including that produced by third-party fundraisers, professional fundraisers and commercial participators.
Existing Code of Fundraising Practice standards apply to AI-enabled fundraising. The revised Code applies to complaints received on or after 1 November 2025 (see the table of changes).
The Charity Commission's AI blog warns of reputational risk from misuse of AI content and that output may infringe copyright.
The guidance also warns that bad actors may misuse a charity's content, and suggests content credentials where proportionate.

What can go wrong

Illustrative scenario: an agency produces an emergency appeal for a charity using AI-generated images of a family in a disaster zone, with no label. A journalist spots the images are synthetic. Donors complain that they gave because they thought they were seeing real people, and the story spreads. The board learns the agency never told the charity it had used AI.

Other risks: a composite case study presented as one person's story, a cloned voice that sounds like a real beneficiary or celebrity, and AI copy that makes a claim about impact the charity cannot support. Scammers can also lift a charity's synthetic imagery for fake appeals; see deepfake and impersonation fraud.

The limits of PI and D&O cover

Most of the fallout here is regulatory and reputational, and insurance has clear limits. Under Charities Act 2011 s.189(2)(a), insurance bought for trustees from charity funds cannot cover criminal fines or regulatory penalties. Loss of donor income and reputational damage are not usually insured losses under charity D&O or PI.

Some D&O wordings pay defence costs for regulatory investigations; whether a Fundraising Regulator investigation counts depends on how the policy defines a regulator or investigation. If a photographer, model or rights holder claims the AI image infringes their rights, the charity may look to media or IP liability cover, which some charity packages include. A third-party claim alleging trustees failed to oversee fundraising could engage trustee indemnity, subject to the terms.

Practical controls

Label AI-generated or altered images, video and voices wherever donors could take them as real.
Say when a case study is a composite.
Require agencies and professional fundraisers to disclose AI use in writing.
Check rights and licences for AI-generated assets.
Have a human sign off every appeal before release.
Publish your AI policy, as the guidance asks; see charity AI policies and the regulator guidance explained.

How Apex helps

Apex arranges D&O, trustee indemnity and PI for charities. A broker can check whether your programme includes regulatory defence costs and media liability, and what it excludes. See the AI in charities hub and the related guide on AI donor profiling.

Sources

Frequently asked

Do we have to label AI images in appeals?

The Fundraising Regulator's guidance says the greater the risk of misleading donors, the more transparent you should be, and that AI images, video and sound that could be mistaken for real people or situations should be covered. Labelling is the practical way to meet that.

Are we responsible if our agency used AI?

Yes. The Fundraising Regulator's guidance says charities are accountable for AI use by third-party fundraisers and for all AI-generated output, extending to contractors, professional fundraisers and commercial participators.

Will insurance cover a Fundraising Regulator complaint?

Not the outcome itself. Charities Act 2011 s.189(2)(a) bars cover for regulatory penalties, and reputational loss is not usually insured. Some D&O policies pay defence costs for regulatory investigations, depending on how the wording defines a regulator.

Can we use AI images to protect a beneficiary's identity?

Yes, and that can be a good reason to use them. The Fundraising Regulator's point is about transparency: if donors could take the image for a real person or situation, say it is AI-generated or illustrative so supporters are not misled about who they are helping.

Check your PI covers how you use AI

Tell us about your firm and the work you do. A broker will review how your current PI treats AI-assisted work, or arrange new cover. No fee for a quote. Or call 0117 325 0027.

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Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information about how AI is used in the profession and how insurance may respond. It is not legal, regulatory or insurance advice on your circumstances, and it does not guarantee that cover will be available or on what terms.