Customer developer docs

FTC Act §5 — Unfair or Deceptive Acts or Practices (AI Substantiation)

FTC Act §5 — AI performance claim substantiation via signed marketing-claims registry plus operational ledger statistics.

FTC Act §5 — Unfair or Deceptive Acts or Practices (AI Substantiation)

Section 5 of the FTC Act prohibits unfair or deceptive acts or practices in commerce. For AI vendors, the most acute obligation is substantiating performance claims — advertising, sales, and demo material must have a reasonable basis in evidence. Ledgix evidences substantiation via a signed marketing-claims registry plus the operational ledger underpinning the referenced metrics.

Status: Full — every control resolves to an artifact Ledgix produces today following the Phase 8 marketing-claims module shipping.

Scope

Section 5 applies to any business engaged in commerce in the United States. In the AI context, the FTC has repeatedly signalled that claims about AI capability, accuracy, or comparative performance must be truthful, non-misleading, and substantiated. Coverage spans substantiation of performance claims, avoidance of unfair practices, avoidance of deceptive representations, and recordkeeping sufficient for investigation cooperation.

Controls covered

FieldTypeRequiredDescription
FTC-S5-SUBST-01marketing_claims / events_jsonlSubstantiation of AI performance claimsSigned registry of active claims with substantiation levels plus aggregate operational statistics.
FTC-S5-UNFAIR-02events_jsonl / policy_snapshotsAvoidance of Unfair PracticesDenial events evidence policy-driven prevention of harmful actions.
FTC-S5-DECEPT-03events_jsonlAvoidance of Deceptive PracticesDecision rationales tied to cited policy text reduce implicit misrepresentation.
FTC-S5-RECORD-04events_jsonl / checkpoint_chain / signaturesRecord-keeping to support enforcement cooperationComplete per-decision record, Merkle chain, and export-level signature.

Evidence types referenced

  • marketing_claims — signed registry entries with claim text, channel, substantiation level, linked evidence, reviewer, and review cadence.
  • events_jsonl — aggregate operational statistics supporting the quantitative portion of substantiation.
  • policy_snapshots — policy text articulating fairness boundaries.
  • checkpoint_chain — Merkle-chained integrity supporting tamper-evidence claims.
  • signatures — export-level signature supporting authenticity of produced evidence.

Known gaps (if any)

None — every control resolves to an artifact Ledgix produces today. Tenants are responsible for populating the marketing-claims registry from their public materials; the admin console provides an import workflow.

Audit pack workflow

Export an evidence ZIP for this framework from the admin console's Evidence Exports panel by selecting FTC Act §5 — Unfair or Deceptive Acts or Practices (AI Substantiation) and a time window. Each control's evidence_locators[] in the included framework_mapping.json points to the corresponding file in the ZIP.

References