Homemade Pasta · Research
Where AI ads are today
One assistant built a billion-dollar ad run rate in about seven months. Google and Microsoft already serve ads in AI answers from campaigns advertisers were running anyway. No platform yet offers a way to show that the spend is incremental.
Executive summary
Nobody can yet show what assistant ads return
- Live: ChatGPT is the only standalone assistant selling ads in volume, and Google and Microsoft sell AI placements by default. OpenAI reports ads in 89 countries and more than 100,000 advertisers since launch. Google AI Mode and Microsoft Copilot serve ads from existing search campaigns, with no separate buy, opt-out or reporting. Meta uses assistant conversations to target ads elsewhere. Perplexity exited advertising, citing user trust.1, 2, 3, 4, 5
- Live: no platform measures incremental return. No assistant offers a lift study, a controlled comparison of people who saw the ads with people who did not. The only independent read of downstream value is a single working paper built on analytics panel data.6
- Coming: the ad unit is moving toward the answer. Google is testing ads inside AI Mode recommendation lists and ad creative written by Gemini. OpenAI is testing conversations with business-sponsored agents, and its automated rewriting of ad copy is already on by default.7, 8, 9
- Research only: in lab studies, assistants told to promote sponsored items steered choices, and labels did not stop them. Auction designs for generating ads inside answers are published and peer-reviewed. In a preregistered experiment with 2,012 participants, an assistant instructed to persuade nearly tripled how often people chose a sponsored item, and labels with a warning did not significantly reduce the effect. No major assistant has shipped this format.10, 11, 12
In paid search, Google’s ad labels shrank from a shaded block to a single word over two decades, about half of UK search users still cannot say why sponsored results sit on top, and field experiments at eBay found true paid search returns at a fraction of what non-experimental estimates showed. Assistant ads face the same pressure on label prominence and on reported returns, from launch.13, 14, 15
Recommendations
Five moves for the next planning cycle
| Move | Why it comes first | Quantified impact |
|---|---|---|
| 1. Map the AI inventory already in your search campaigns | The placements are already in most search plans. AI Mode reports more than a billion monthly users, and every eligible Microsoft campaign serves in Copilot. See 1.1.3, 16 | Match type is the remaining control. Broad match, AI Max (Google’s automated query expansion) and Performance Max can match on conversational context; exact and phrase match qualify only when the query itself is commercial.17 |
| 2. Size a ChatGPT test as a learning budget | Early spend buys a year of learning about prompts, formats and audiences before the channel matures. Return is not yet measurable. See 1.2. | At one advertiser’s reported $1.72 cost per click and a 0.37% conversion rate, $20,000 buys about 43 conversions, a count that can swing ±30% on chance alone. The model in 1.3 sizes this against your own numbers. |
| 3. Judge the test against a holdout in backend data | ChatGPT’s reported totals changed basis on September 30, 2026, when view-through conversions (sales credited to an ad seen but not clicked) were added. Totals may also include modeled, meaning estimated, conversions.18, 19 | A geo or audience holdout, read in backend sales data, is the only design that separates new sales from sales that would have happened anyway. See 4.1 for what paid search experiments found. |
| 4. Set a policy on automated ad creative | OpenAI’s system can change ad copy and destination URLs without per-version approval, and Google is testing AI Mode ads that Gemini writes. See 2.2. | In regulated categories, an unreviewed claim is a compliance exposure. OpenAI’s setting switches off at account or campaign level, and the decision belongs in the same review process as any other ad copy. |
| 5. Fund the organic answer as a separate line | OpenAI states that ads do not influence ChatGPT’s answers. If that holds, an ad buys a slot beneath the answer and nothing inside it. See 3.3.20 | Treat assistant ads as media and presence in the answer as content and earned coverage, with separate budgets and KPIs so neither gets credit for the other. The AI Overviews research covers the organic side. |
Part One
What is live now
What is live today, who sees the ads, how they are bought, and what the reporting shows.
1.1 Platforms
Two of the three assistants with ads sell them by default
Three assistants carry ads today. Only one sells them as a product of their own. The other two treat AI answers as additional inventory for search campaigns, which means many advertisers are already buying AI placements without having chosen to.
| Assistant | Status | Who sees ads | Format | How it is bought | Reporting |
|---|---|---|---|---|---|
| ChatGPT | Live 89 countries |
Free and Go tiers. Not Plus, Pro, Business, Enterprise or Edu. Not accounts identified as under 18. Not beside health, mental health or political conversations.1, 21 | A labeled unit beneath the answer, visually separated. One unit can hold several advertisers. | Self-serve Ads Manager in beta, a public Advertiser API, agency and technology partners, and a pilot through Amazon DSP. CPM or CPC.18, 22, 23 | Pixel and Conversions API. 30-day click, 1-day view default. Totals may include modeled conversions.19 |
| Google AI Mode | Live US and 10 markets |
Search users in eligible markets. Testing since October 16 with users who connect Gmail and Photos through Personal Intelligence.24, 25 | “Sponsored” units below and within answers, shopping ads, and in the US, multiturn ads that can appear in answers to follow-up questions. | Existing Search, Shopping, Performance Max and AI Max campaigns. No standalone buy, no exclusion.2 | Folded into standard campaign reports. No AI Mode segment.17 |
| Microsoft Copilot | Live | Copilot users. No personalized ads for signed-in users under 18. No ads in conversations flagged as potentially harmful.3, 26 | Beneath the response, introduced by a short “ad voice” summary. Multimedia, product and search ads with a logo.3, 27 | Every eligible Microsoft Advertising campaign, opted in automatically. Advertisers cannot opt out. | “Does not currently support specific metrics for ads served in Copilot.”3 |
| Meta AI | Live as a signal |
No ads inside the assistant. Since December 16, 2025, conversations with Meta AI personalize ads on Facebook and Instagram, excluding sensitive topics. Reported exemptions: EU, UK, South Korea.4, 28 | None in the assistant. | Not targetable directly. The signal feeds existing Meta ad delivery. | No disclosed effect on ad performance. |
| Gemini app | Announced open to ads |
No ads. Google said in December 2025 it had “no current plans”; by April 2026 it described itself as open to them.29 | No ad product. | ||
| Perplexity | Stepped back exited |
Stopped accepting new advertisers in October 2025. Executives told the Financial Times in February 2026 that ads had been wound down because they made users doubt the answers.5 | No ad product. | ||
| Claude | Stepped back declined |
Anthropic committed on February 4, 2026 to keeping Claude ad-free, funded by subscriptions and enterprise contracts.30 | No ad product. | ||
| Grok | Announced stated intent |
Elon Musk told advertisers in August 2025 that paid placements would appear in Grok’s answers. No launch has followed.31 | No ad product announced. | ||
ChatGPT’s first nine months
By OpenAI’s own figures the ramp outpaced both paid search and social advertising, and it was built on infrastructure those platforms spent two decades developing: a self-serve interface, an API, agency deals, CPC bidding, a pixel and a conversions API.
All dates 2026. Revenue and advertiser figures are OpenAI’s own statements, relayed by the outlets cited.
What the shipped ad unit looks like in practice
An academic audit ran 91 synthetic ChatGPT accounts through roughly 128,000 conversations between February and May 2026. The first ads appeared on March 8. From then to the end of March, ads appeared in 5.6% of conversations. No account saw an ad in its first seven days, and the median account waited 14 days. Once an account began seeing ads, the median rate rose to 24% of prompts.37
Every ad observed was a single labeled unit at the foot of the conversation, linked to a brand rather than a specific product. Ads were most frequent on product, fitness and cooking prompts, at roughly 10% to 14% of sessions, and near zero on the health, mental health and political topics OpenAI said it would exclude. Retailers led the advertiser list.
Later third-party counts are higher and use different definitions. One vendor panel found sponsored units on 26% of US desktop responses to Free and Go users in June. A second study found ads on 26% of commercial prompts in ChatGPT and 29% in Google AI Mode. A third estimates that 43% of ad-eligible US users had seen at least one ChatGPT ad by September.38, 39, 40 None of these figures measure the same thing, and none should be compared with another as a trend.
What each platform does with conversation data
OpenAI. With ad personalization on, past chats, memory and earlier ad interactions can inform which ad appears. With it off, selection uses the current conversation, approximate location and language. Personalized ads were not initially offered in the EEA or Switzerland. Advertisers receive aggregated performance data, not conversations.21
Google. A privacy policy update effective October 16, 2026 allows Search to use data people let it access to personalize ads. Google says ads are not based directly on Gmail or Photos content, while summaries and inferences from connected apps may be used for users who opt in.25, 41
Microsoft. Where a user’s ad and Copilot personalization settings allow it, Copilot conversation history informs the ads that user already receives.26
Meta. Voice and text conversations with Meta AI inform content and ads, excluding conversations about religion, sexual orientation, politics, health, ethnicity, philosophical beliefs and union membership. A coalition of 36 advocacy groups asked the FTC to halt the practice in October 2025.4
1.2 Return
Incremental return is the missing measurement
Every number about assistant ad performance currently comes from one of three places: the platform itself, a vendor that sells services in the category, or a single working paper. None comes from a controlled test of whether the ads produce sales that would not otherwise have happened.
A vendor panel measured click-through by market
A panel run by Similarweb and the growth agency Graphite tracked ChatGPT ad exchanges from March 30 to September 16, 2026. Click-through ran highest in Latin America and lowest in English-speaking markets, though the Latin American markets launched months later, so the comparison is not like-for-like. Worldwide click-through rose 112% across the period.40
Click-through per ad-bearing exchange, pooled across advertisers. Bar length scaled to 2.0%.
One working paper measured what the clicks were worth
Researchers at WU Vienna and the Frankfurt School compared US advertisers buying both paid ChatGPT and paid search, using analytics panel data from Grips Intelligence. A paid ChatGPT visit produced about a third of the revenue of a paid search visit and converted at about a third of the rate.6
Revenue per visit
Conversion rate
Results were concentrated. Of 87 advertisers buying both channels, 73 recorded no paid ChatGPT transaction during the window, and a single advertiser accounted for 66% of paid ChatGPT purchases. Organic ChatGPT referrals to the sites in the panel fell 5.9% after ads launched, an estimate whose confidence interval includes zero. The paper is not peer reviewed.
The baseline behind each platform claim
| Platform | Claim | Basis |
|---|---|---|
| OpenAI | “No impact on consumer trust metrics, low dismissal rates of ads.” | Internal, March 2026. No figures published.34 |
| Microsoft | 73% higher click-through and 16% higher conversion rates than traditional search. | First-party, February to May 2025, against an undefined search baseline.42 |
| Sponsored and organic product listings in AI Mode have “similar” click-through rates. | Internal, US, August 20 to September 3, 2026. No figures published.24 |
OpenAI’s help center, as reported by Search Engine Journal, states that ChatGPT ads have no performance benchmarks across advertisers, industries or campaign types.40
Prices reported so far
ChatGPT launched on CPM pricing near $60. By mid-April, a named agency executive put average CPMs near $45, and anonymous sources described offers of $25 to $35 through a technology partner. CPC bidding arrived on May 5. One advertiser account reported paying $1.72 per click in June, and OpenAI’s suggested opening bid was reported at $3 to $5.6, 33
Self-serve minimum daily budgets vary by currency and are not published; the API returns the required amount when a budget falls short. A daily budget is treated as a seven-day average, so a single day can spend up to twice the figure.18, 43 Google and Microsoft price AI placements inside their existing search auctions and publish no separate rates.
1.3 Test sizing
What a learning budget can tell you
A first test in a new channel buys learning about reach, prompts and creative. Whether it can also judge cost per acquisition depends on how many conversions it produces, because small counts move a long way on chance alone. The model below starts from one advertiser’s reported cost per click and the working paper’s conversion rate. Replace both with your own.
Clicks, conversions, and how far the conversion count could move by chance.
Enough conversions to see direction. Too few to compare cost per conversion with search. Pair the test with a holdout before scaling it.
Part Two
What is in test
Formats in test or announced, and the direction they move the paid unit.
2.1 Formats
The ad unit is moving toward the answer
Most formats shipped so far sit beneath the answer. The formats in test move the paid unit into the answer’s own lists, hand its wording to the platform’s model, and turn the click into a conversation.
| Development | Status | What changes for the advertiser |
|---|---|---|
| Highlighted Answers, Google AI Mode | In test | Ads appear inside AI Mode’s own recommendation lists rather than beneath them.7 |
| Conversational Discovery ads, Google AI Mode | In test | Gemini writes ad creative that answers the person’s specific question, so the platform’s model sets the final wording.7 |
| Shopping ads in the body of AI Mode answers | In test | Product ads move from below the response into it. Reported in trade press from August 31, 2026, without a clear test or rollout status.17 |
| Multiturn ads, Google AI Mode | Live | US only. Ads can appear in answers to follow-up questions, so the whole conversation becomes the targeting context.24 |
| Direct Offers, Google AI Mode | In test | Exclusive discounts shown to shoppers judged ready to buy, which makes price part of the placement.7, 44 |
| AI-powered Shopping ads and Business Agent for Leads | Announced | Described in May 2026 as arriving “in the coming months.”7 |
| Sponsored Agents, ChatGPT | In test | Select US advertisers. After a relevant ad, a person can open a labeled conversation with an agent the business sponsors, separate from the original chat.8 |
| Offer Highlights, Copilot | Announced | Announced in April 2026 for retailers in English-speaking markets: product differentiators promoted inside Copilot conversations, supplied through Microsoft Merchant Center.45 |
Meta has announced no plan for ads inside Meta AI. Its earnings calls through October 2026 describe the assistant as free at the core, with subscriptions and, for its shopping agent, possible commissions as the way it earns money.28
2.2 Creative
The platform now writes part of the ad
OpenAI switched on “creative enhancements” for new and existing self-serve campaigns on October 30, 2026. The system can rewrite headlines and descriptions, translate ad text, resize images and change destination URLs. Variations can be generated in real time from the conversation, and enhanced versions “can run automatically without requiring you to review or approve each version.” Advertisers can switch the feature off for an account or a campaign.9
Google is testing Conversational Discovery ads in AI Mode, with creative Gemini writes to answer the person’s question. In AI Overviews, some sponsored placements already carry short Gemini-written descriptions that advertisers cannot edit or opt out of. AI Mode itself cannot be excluded from the campaigns that feed it.2, 7
In financial services, health, education and other regulated categories, this creates compliance exposure. The approved claim and the served claim can now differ without anyone at the advertiser seeing the served version.
Early evidence on machine-written ads
Criteo reported that its query-specific ChatGPT creative produced about four times the spend after activation, with no baseline stated. The figure measures spend only.46
In a lab setting, people choosing between two ads for a fictional product picked the AI-written version 59% of the time, driven by authority and consensus framing. Participants who believed the AI-written ad came from a person picked it 72% of the time. The study measured stated preference only.47
Part Three
What exists only in research
Ad designs from research papers, and what lab studies found about how users respond.
3.1 Designs
The research assumes the ad is written into the answer
Shipped formats keep ads outside the generated text. Most academic and industry-lab work on selling ads in assistants assumes the advertiser’s message is generated into the answer, with the auction pricing what the model writes.
Each advertiser is represented by its own language model. At every word, the mechanism blends the advertisers’ preferred next words, weighted by their bids, and samples from the blend. Google’s worked example is a single slot for “Vacations in Hawaii” with two hypothetical advertisers. As the bids shift, the output moves from one advertiser, to a jointly written sentence (“Alpha Airlines flies you to Hawaii where you can enjoy a magic weeklong experience at Beta Resort”), to the other.
Google describes the examples as purely hypothetical and not an announcement of changes to Google Ads.10
A second design, presented at NeurIPS 2024, runs a separate auction for each segment of an answer, such as a sentence or a paragraph, and prices each placement per click. The simulations put numbers on a tradeoff for any platform that sells ads inside answers. Auctioning one ad per segment earned 0.371 in expected revenue against 0.238 for bundling several ads into one placement, about 36% less. The bundled version produced answers closer to what the model would have written with no ads at all.11
Where the auction designs are heading
Alibaba’s advertising group has gone further, training the language model itself to act as the auction. In simulation it produced more revenue per query than earlier published designs.48 A 2026 proposal takes the route closest to what ChatGPT shipped: generate the answer first, insert a disclosed ad afterward, and let advertisers bid on clusters of similar conversations rather than individual prompts.49
Every performance figure in this literature is simulated. None of these designs has been tested on a live assistant.
3.2 Users
Assistant persuasion nearly tripled sponsored choices in a controlled test
The most direct test of what happens when an assistant has a commercial interest comes from a preregistered Princeton experiment. In it, 2,012 US participants chose a free book from about 5,500 titles, either through a search interface or through a chat assistant running one of five leading models. One title in five was secretly marked as sponsored, so a random pick lands on a sponsored title 20% of the time.12
Placement alone, in search or in chat, moved choices only a few points above chance. Persuasive language from the assistant nearly tripled the search figure. The assistants used ordinary sales technique, talking up the sponsored option and hedging on the alternatives.
Three smaller studies found the same pattern
In a University of Michigan experiment with 179 participants, about half did not realize an assistant was serving them ads, perceived answer quality did not differ significantly between ad and no-ad versions, and only four of the participants shown a disclosure link clicked it.50 In a German study of 175 participants, many did not notice brand placements in generated answers, and ratings barely changed after the placements were disclosed.51 A sandbox test of 23 language models found that 18 recommended a more expensive sponsored flight more than half the time when the system prompt suggested it, at rates as high as 83% for some models and as low as 28% for others, and steered users who appeared higher-income toward the sponsored option more often, 64% against 49%.52
What disclosure research predicts
A meta-analysis of 61 papers on sponsored content found that disclosure reliably raises recognition and resistance, and lowers credibility and brand attitudes.53 That gives any platform a commercial reason to prefer subtle labels.
In a preregistered UK experiment with 1,500 adults on political persuasion, labeling the chatbot as AI had no effect. Telling people what the chatbot had been instructed to argue roughly halved its persuasive effect, from 12.6 to 6.3 points on a 100-point scale.54 The finding has not been tested on commercial persuasion.
3.3 Organic answers
Organic answers can already be steered without buying an ad
- Adding quotations, statistics and citations to a source raised its visibility in generated answers by up to about 40%, with the largest gains for lower-ranked sources.55
- In 2024, text written to manipulate preferences made Bing Copilot recommend a test product about 2.5 times as often as a comparable one, and lifted a fictitious camera from 34.0% to 59.4% of recommendations. When several sellers tried the same tactic, all of them lost visibility. Microsoft said it was adding protections.56
- Across repeated runs of the same product query, ChatGPT’s recommended product sets overlapped by 0.178 on average, Gemini’s by 0.287 and Google AI Overviews’ by 0.421. Among ChatGPT responses that named products, 73% labeled one “best.”57
- Models from OpenAI, Anthropic and Google ranked their own companies’ products about 0.2 positions higher than benchmark performance justified.58
Share of answer, the rate at which a brand appears in responses, is volatile before any ad runs. A test that compares organic mentions before and after an ad campaign needs a large, fixed set of prompts and a control period long enough to absorb that noise.
Part Four
Where it is heading
The paid search precedent, the money, what changes when an agent does the shopping, and the signals that would move a claim from one stage to the next.
4.1 Precedent
Paid search faced the same questions twenty years earlier
Between 1998 and 2015, search advertising worked through whether people can tell paid results from organic ones, how prominent the label must be, and whether platform-reported returns hold up under testing.
The FTC set the disclosure standard in 2002
In 2002 the FTC told search engines to “clearly and conspicuously disclose” paid placement, using terms that convey the ranking is paid for.59 In 2013 it warned that paid results had become “less distinguishable as advertising,” and stated that its guidance applies “regardless of the precise form that search takes now or in the future.”60 FTC business guidance published in 2023 extended the principle to generative AI: output should distinguish clearly between what is organic and what is paid.61
Google’s ad label shrank over two decades
More from the labeling record
Ben Edelman, a researcher who discloses consulting work for Google competitors, documented one advertiser’s report that when Google removed the shading, paid clicks rose to as much as 75% above organic before mostly reverting within about three months.62 Label wording alone moves clicks. Replacing “Sponsored links” with “Paid Advertisement” cut ad clicks by 25% in a randomized test.63
In a representative German survey from 2013, 62% could not reliably distinguish ads from organic results.64
Recognition never caught up
After more than two decades of paid search, 51% of UK search users can correctly say why the top sponsored results are there, against 54% in 2023 and 48% in 2018. Among 16 to 24 year olds the figure is 37%.14
Attributed returns overstated true returns
Field experiments at eBay found paid search returns at a fraction of conventional non-experimental estimates. Brand-keyword ads showed no measurable short-term benefit, and heavy repeat buyers who would have purchased anyway absorbed most of the spend.15 A randomized experiment on a restaurant search app found the reverse error. Labeled ads raised calls to advertisers mainly through exposure rather than clicks. Click-based attribution would have under-credited those ads, and last-click reporting would have assigned much of their effect to organic listings.65
4.2 Money
2030 estimates run from $5 billion to $100 billion
Forecasts for assistant advertising disagree by a factor of nearly twenty. Most of the gap is scope. The low figure covers US standalone chatbots, while the high figures are global and include either AI search placements or one company’s own plan.
The largest market-wide number mostly reclassifies existing search spend. More than 80% of EMARKETER’s $32.03 billion for US “AI advertising” in 2026 is ordinary search advertising shown next to an AI-generated summary. Its estimate for ads inside standalone chatbots is under $1 billion for 2026.66 OpenAI told investors it expected $2.5 billion in ad revenue in 2026. After the $1 billion run rate at the end of August, EMARKETER’s principal analyst called that target “all but impossible.”68, 70
ChatGPT ads reached $1 billion faster than search or social ads did
A run rate annualizes the latest period, so it overstates a first year of revenue. OpenAI also launched into an audience of roughly a billion weekly users with self-serve tools, an API and agency relationships that did not exist in 2000 or 2007. Google’s revenue grew fivefold in 2002, the same year AdWords moved to click-based pricing that factored click-through into ad rank, and ChatGPT made the same move from CPM to CPC bidding within three months of launch.22, 72
The audience the forecasts rest on
Search behavior has shifted only slightly. AI tools accounted for 1.65% of US desktop search-like activity in the first quarter of 2026, up from 1.31% a year earlier, while Google held 94.3% of US desktop search.16, 74, 75, 76, 77 Alphabet reported its fastest search query growth in five years in October 2026.75 A widely cited 2024 Gartner prediction that traditional search volume would fall 25% by 2026 has not materialized on these measures.78
Assistant use also skews away from shopping. In a study of ChatGPT messages co-authored by OpenAI researchers, practical guidance, writing and information seeking account for nearly 80% of use, with product queries a subset of information seeking.79 The inventory that carries commercial intent is a minority of the conversations.
4.3 Agents
Platform badges outweighed ad labels in agent simulations
The payment rails for agents buying on a person’s behalf are built. OpenAI’s Agentic Commerce Protocol with Stripe, Google’s Agent Payments Protocol and Universal Commerce Protocol, Visa Intelligent Commerce and Mastercard Agent Pay all launched between April 2025 and January 2026, and Mastercard reported the first agent-initiated transaction on its network in the third quarter of 2025.44, 80, 81, 82
Purchase volume has lagged behind the infrastructure. In March 2026 OpenAI scaled back Instant Checkout inside ChatGPT. Etsy described the resulting sales volume as small, and Walmart saw conversion inside the chatbot run three times lower than when shoppers clicked through to its own site. OpenAI shifted toward retailer apps inside ChatGPT and merchants’ own checkout.83 In US surveys, 6% to 11% of adults report having completed a purchase through an AI tool, and about one in ten would let an agent complete a purchase on its own.84
Researchers ran six models through randomized choices in a mock storefront across eight product categories. A “Sponsored” tag lowered a product’s chance of selection in each model in the first round of tests, from an illustrative 10% baseline to between 7.9% and 8.9%. A platform “Overall Pick” badge raised it to between 19.9% and 42.6%.
Model updates reshuffled outcomes. One brand of watch won 45% of choices under one model, 77% under a newer model from the same company, and about 6% under a competitor’s. A seller rewriting its product description with AI gained up to about 15 points of share.85
If those patterns hold outside a sandbox, an ad label is a mild penalty when an agent chooses, and influence shifts to platform endorsements, product data and how quickly a merchant responds. Economists studying agent markets expect agents to resist advertising that carries no information or signaling value.86 Publishers are already experimenting with ads written for AI crawlers, with no measurement standard yet in place.87
The 2030 sizing estimates
Estimates of US agentic commerce in 2030 run from $190 billion to $385 billion (Morgan Stanley) to $900 billion to $1 trillion (McKinsey), depending on whether purchases the agent only influenced are counted. None of them measures checkouts the agent completed.88
The first appeals ruling on a shopping agent
In August 2026 the Ninth Circuit vacated an injunction that had blocked Perplexity’s Comet agent from shopping on Amazon, holding that “it is the user who ‘accesses’ Amazon’s computers, with the help of the Assistant.” The court said it was not establishing a new legal regime for agents.89 If that reasoning holds, the person remains the legal actor, which keeps disclosure duties pointed at what the person sees.
4.4 Signals
Six signals that would move a claim up a stage
Each of these is an observable event that would change what an advertiser should do.
| Signal | Today | What it would change |
|---|---|---|
| An assistant offers a lift study or a clean room, a privacy-safe environment for matching ad exposure to sales | None offered | Spend could be judged on incremental return rather than platform attribution. |
| Google or Microsoft adds an AI segment or an opt-out | Neither offered | AI placements could be priced, bid and judged separately from search. |
| Ads appear in the Gemini app | No ads; Google open to them | The Gemini app, with more than a billion monthly users, becomes buyable inventory, likely through existing Google campaigns. |
| Paid content appears inside answer text on a major assistant | Research only | The persuasion and detection findings in Part Three stop being hypothetical, and disclosure enforcement becomes the issue. |
| ChatGPT is designated a very large online search engine in the EU | Under Commission review | A public ad repository opens competitive visibility into who advertises on ChatGPT, and with what. |
| Agent-completed checkout returns at volume | Scaled back, March 2026 | Placement inside an agent’s selection becomes something to buy, and product data quality starts to affect media results. |
Appendix
Back of house
The source behind each figure.
A.1 Sources
Where every number comes from
Numbered references appear inline throughout. Each entry gives the date, the kind of source, and, for research, whether it has been peer reviewed. Many of the 2026 academic sources are preprints, and several platform figures reach the public only through trade press relaying company statements.
Source register
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