Welcome to the forefront of conversational AI as we explore the fascinating world of AI chatbots in our dedicated blog series. Discover the latest advancements, applications, and strategies that propel the evolution of chatbot technology. From enhancing customer interactions to streamlining business processes, these articles delve into the innovative ways artificial intelligence is shaping the landscape of automated conversational agents. Whether you’re a business owner, developer, or simply intrigued by the future of interactive technology, join us on this journey to unravel the transformative power and endless possibilities of AI chatbots.
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The UK government’s decision to bring AI chatbot providers under the Online Safety Act is not just a child protection story it’s a compliance wake up call for affiliate managers running creator-led programs, that deserves urgent attention. On 15 February 2026, Prime Minister Keir Starmer announced that AI chatbot providers, including tools widely used by content creators such as ChatGPT, Google Gemini, and Microsoft Copilot, will be required to abide by the illegal content duties already imposed on social media platforms under the Online Safety Act. The government has stated that non-compliant platforms will face the legal consequences of breaking the law, and has indicated it intends to move at pace rather than wait for new primary legislation to catch up with evolving technology.
It’s the last detail in that statement that matters which affiliate marketers need to be aware of.
The government is pursuing amendments to the Crime and Policing Bill specifically to avoid the slow machinery of new legislation. Ministers have said they want the ability to act on regulatory findings within months, not years. For performance marketing professionals, that timetable is effectively now.
The immediate focus of the announcement is on illegal content, specifically AI-generated material that sexualises minors, deepfakes produced without consent, and chatbot outputs that circumvent existing child safety frameworks.
The Grok controversy, in which Elon Musk’s AI chatbot on X was found generating sexualised images before the function was removed following government pressure, provided the catalyst. The European Commission had also opened an investigation into X in January over related concerns, and Ofcom in the UK had already begun its own probe.
But the regulatory logic runs deeper than a reaction to a single scandal. As one legal analysis from CMS noted, the Online Safety Act in its current form is built around regulating services rather than technologies, meaning AI chatbots that only allow interaction between a user and the chatbot itself, not between multiple users, had previously fallen outside the Act’s scope. The government is explicitly closing that gap.
For affiliate managers, this creates a different kind of exposure than the one making headlines. The question is not whether your program is generating illegal content. The question is whether you have adequate visibility into how the content creators you work with are using AI tools, what that content looks like before it reaches audiences that may include minors, and whether your affiliate terms and conditions place any obligations on partners at all in relation to AI-generated content.
The growth of AI-assisted content creation among publishers and influencers has been rapid. Creators across YouTube, TikTok, Instagram, and blog-based channels are routinely using generative AI for scripting, voiceovers, image generation, video editing, and even full article production. Much of this is legitimate and lawful. But the regulatory environment is tightening precisely because the tools have outpaced the rules, and programs that have not updated their terms to reflect this reality are operating in a gap that regulators are starting to close.
We have previously covered TikTok’s tightening of AI content rules and YouTube’s monetisation crackdown on AI-generated content. The pattern is consistent: platforms are enforcing higher content standards and requiring disclosure of AI usage because advertisers and regulators are demanding it. The UK government’s announcement extends that accountability up the chain to the tools themselves.
For affiliate program managers, the practical risk is straightforward.
If a creator partner is using an AI tool to produce content that falls foul of the Online Safety Act, either through generating harmful material targeted at audiences that include under-16s or through producing undisclosed AI content that misleads consumers, the liability question does not stop with the creator. Brands and program managers who lack documented oversight processes, and who have no contractual requirements in place, are exposed.
This is not a hypothetical. As we noted in our analysis of ethical affiliate marketing in the age of AI, the compliance blind spot around how partners use AI tools, including the risk that automated or AI-generated content slips through without proper vetting, is already creating legal exposure for programs in regulated verticals. The UK government’s announcement puts that risk on a much clearer legal footing.
The government has also announced a consultation, launching in March, that will consider a minimum age of 16 for social media access, restrictions on features like infinite scrolling, limitations on children’s use of AI chatbots, and options around VPN restrictions. The consultation draws on Australia’s approach, where a social media ban for under-16s has already forced platforms to implement age verification across YouTube, Instagram, TikTok, and Facebook.
If the UK moves in a similar direction, the implications for affiliate programs running creator campaigns on social platforms will be substantial. Audience composition, age-gating of content, platform eligibility, and disclosure obligations will all be in play. Programs that reach audiences with products aimed at or potentially consumed by minors, including gaming, health, beauty, fashion, and finance verticals, will need to examine their creator partnerships through a new lens.
Google’s evolving stance on AI content quality already signals that search visibility for AI-generated content without sufficient human value is at risk. Add UK regulatory enforcement to that equation, and the case for having documented AI content policies within your affiliate terms becomes considerably stronger. The government’s broader push also raises a question that affiliate managers running creator programs in the UK need to consider: does your program know, with any degree of confidence, what AI tools your partners are using, what those tools are generating, and whether that content meets current and forthcoming UK legal standards?
The gap between how affiliate programs were designed and how creators now operate is significant. Most standard affiliate agreements were drafted before generative AI became a routine production tool. Very few contain explicit clauses about AI content usage, disclosure obligations, or the standards creators must meet when using AI to produce content that carries affiliate links or brand associations.
That needs to change. As the regulatory environment tightens, affiliate terms and conditions should now address several specific areas.
Partners must be required to disclose AI-generated content in line with both platform rules and emerging UK legal obligations. Programs should specify which categories of AI-generated content are permissible, particularly for regulated verticals, and which are not. Terms should require that creators retain responsibility for ensuring AI tools they use comply with applicable law, including the Online Safety Act as it now applies to chatbot providers.
Programs working with creators whose audiences include or may include under-16s should be particularly attentive to where their content lives and how it is produced. The government has been explicit that the upcoming consultation will consider restrictions on children’s access to AI chatbots specifically, meaning the content environment in which those tools operate is going to become more tightly regulated in the months ahead.
Our previous coverage of faceless affiliate marketing highlighted the compliance challenge that arises when anonymous, AI-assisted creators operate at volume without verified contact details or clear accountability. The UK government’s direction of travel makes that model more legally precarious, not less. For program managers who have not reviewed their partner agreements recently, it is also worth revisiting how your onboarding process captures information about the tools and methods creators use to produce content. Documented oversight is not about policing creative process. It is about being able to demonstrate, if you are ever asked by a regulator, that your affiliate program operates within the legal framework that governs the content your partners publish.
Review and update your affiliate terms. Add explicit clauses covering AI content usage, disclosure requirements, and compliance obligations under the Online Safety Act. Ensure partners acknowledge these terms as part of their program agreement. Consult your legal team, particularly if you operate in regulated verticals.
Audit your creator partner mix. Identify which partners are producing AI-assisted content, what platforms that content lives on, and what audiences it reaches. For any creator whose audience composition is unclear, particularly around age demographics, flag that relationship for closer review given the forthcoming social media age consultation.
Build a disclosure standard into your program. Require creators to label AI-generated content in line with current platform requirements and UK regulatory expectations. YouTube’s AI disclosure requirements and TikTok’s Content Disclosure Settings already set platform-level precedents. Your program terms should mirror and reinforce those standards rather than leaving creators to navigate them alone.
The UK government has made clear that technology companies will not be given the latitude to self-regulate their way through the AI era when children’s safety is at stake. Affiliate programs working with content creators have a responsibility to apply that same standard of accountability to their own partner relationships. The compliance gap in how programs govern AI content usage is close-able. The question is whether program managers act before they are required to, or simply react after something goes horribly wrong?
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