- Does this news really affect me, or is it just an issue for American creators?
- How exactly does Substack's Pangram tool work?
- What the data says: how big is the gap between those who use AI and those who trust AI?
- Why it's being talked about now: is Substack really relevant for the Italian market?
- What the law requires: is the EU AI Act already in force?
- Three real-world scenarios: what changes for an Italian SME that uses newsletters and AI content?
- What tools and approaches exist to manage AI transparency in content?
- What real risks do you run if you ignore this trend?
- Where to start: practical steps to manage AI transparency in your communications
- What mistakes are made most often when tackling this topic?
- How can you tell whether your AI policy is really working?
- So, is AI transparency really worth it for your company?
- How we see it at SHM
- Frequently Asked Questions
- Substack has integrated Pangram, an AI detection software that estimates the percentage of AI-generated content in posts and newsletters: the result is visible only to the person who requests the scan.
- Since August 2, 2026, Article 50 of the EU AI Act imposes disclosure obligations for AI-generated texts on topics of public interest, with fines of up to 15 million euros.
- 72% of marketers are calling for an industry standard for AI disclosure in ads: transparency is becoming a competitive metric, not just a regulatory obligation.
Updated October 16, 2026
83% of marketing executives already use AI in the creative process, but only 45% of consumers have a positive perception of AI-generated content. Substack has just made this gap visible to everyone.
Does this news really affect me, or is it just an issue for American creators?
It concerns anyone who uses a newsletter as a channel to engage clients and prospects, in Italy and elsewhere. When a platform with millions of creators adopts a standard, others follow.
On July 22, 2026, Substack made a new feature public: a tool to estimate the extent to which a piece of content was written or assisted by artificial intelligence. As reported by TechCrunch, the platform has integrated Pangram, an AI detection software that analyzes posts, notes, replies and comments of at least 100 characters and returns a percentage estimate of AI-generated content.
The result is visible only to the user who requests the scan, not to the general public. But the signal is clear: AI transparency is no longer optional.
For an Italian marketing manager, this is not a technical detail. It directly affects your brand's credibility and your relationship with the people who read your communications.
| Your situation | Worth acting? | why |
|---|---|---|
| You use newsletters as a B2B or B2C channel | Yes | Editorial credibility is an asset: better to define your AI policy right away |
| You produce content with partial AI support | Yes | A voluntary label protects you from Pangram misclassifications |
| You don't use AI in your content | Yes | You can use transparency as an explicit competitive advantage |
| You run ad campaigns with AI-generated creatives | Yes | The EU AI Act imposes disclosure obligations from August 2, 2026 |
| You're only on platforms other than Substack | A middle ground | The standard will spread: better to prepare now than play catch-up |
How exactly does Substack's Pangram tool work?
Pangram analyzes texts published on Substack after July 2026 and estimates the share of AI-generated content. Creators can add a voluntary label or dispute an incorrect classification.
Pangram is AI detection software, meaning a program that analyzes the style and structure of a text to estimate whether it was written by a human or generated by a language model such as ChatGPT or Claude.
According to Gazetteer SF, the feature works only on content published after the July 2026 announcement. Earlier posts remain unverifiable on the platform.
- 1 · Reader or creatorRequests the scanSelects a post, note or comment of at least 100 characters and starts the Pangram analysis.
- 2 · PangramEstimates the AI percentageThe software analyzes the text and returns an estimate of the share of AI-generated content.
- 3 · CreatorAdds the voluntary labelBefore publishing, they can explicitly declare the use of AI in the content.
- 4 · CreatorDisputes the classificationIf they believe Pangram has misclassified their text, they can request removal of the result.
One important point: as MyStartupNews notes, creators can dispute an incorrect classification. This matters because AI detectors aren't infallible: a very polished, formal text can be classified as AI-generated even if a human wrote it.
What the data says: how big is the gap between those who use AI and those who trust AI?
83% of marketing executives already use AI in the creative process, but only 45% of consumers have a positive perception of AI content. That gap is the problem to solve.
The most telling figure isn't 83%. It's the gap between 82% and 45%: advertisers believe almost all consumers feel positive about AI in content, but reality is nearly the opposite. This misperception is costly: it leads to communication choices that erode trust instead of building it.
Trust, after all, is already under pressure. According to the Edelman Trust Barometer 2026, which surveyed almost 34,000 people in 28 countries, nearly 7 in 10 respondents fear that institutional leaders deliberately mislead the public. In this climate, transparency about AI isn't an optional ethical gesture: it's a concrete way to stand out.
Why it's being talked about now: is Substack really relevant for the Italian market?
With over 100,000 monetizing publishers and an average open rate of 44%, double the email average, Substack has become a benchmark for all newsletter content marketing.
In June 2026, Substack passed 100,000 publishers earning through subscriptions, with 5 million active paid subscriptions. The average email open rate is 44%, about double the industry average.
These numbers explain why Substack's move matters even if you don't use Substack. When a platform of this scale adopts a standard, in this case AI disclosure, it effectively turns it into a market expectation. Beehiiv, LinkedIn Newsletters, traditional email marketing platforms: they will all have to answer the same question.
For an Italian company that uses its newsletter to build relationships with customers and prospects, the question isn't “Should I be on Substack?” The question is: “Is my AI content policy clear, consistent and communicated?”
This applies to anyone running paid media campaigns too. As we discussed in our piece on Gemini and AI image generation for content marketing, AI is already part of almost everyone's creative process. The real question is how to communicate it.
What the law requires: is the EU AI Act already in force?
Yes. As of August 2, 2026, Article 50 of the EU AI Act applies and imposes disclosure obligations for AI-generated text on matters of public interest, with fines of up to 15 million euros.
The AI Act, the European regulation on artificial intelligence, is no longer a future prospect. As Baker Botts explains, Article 50 became applicable on August 2, 2026 and covers anyone who publishes AI-generated text on matters of public interest.
“Public interest” is a broad category: it includes health, finance, law and politics, but also communications that influence major purchasing decisions. If your company produces content on these topics with AI support, disclosure is no longer a choice.
| Obligation | Who it applies to | Maximum penalty |
|---|---|---|
| Disclosure of AI-generated text on matters of public interest | Operators publishing AI content in the EU | 15 million euros or 3% of worldwide turnover |
| Labeling of synthetic content (deepfakes, AI images) | Anyone distributing manipulated content | 15 million euros or 3% of worldwide turnover |
| Disclosure of the use of high-risk AI systems | Companies using AI in significant decision-making processes | 30 million euros or 6% of worldwide turnover |
The rule doesn't ban the use of AI: it requires you to disclose it. For many Italian companies, the first step is to work out which content falls within its scope and update internal policies accordingly.
Three real-world scenarios: what changes for an Italian SME that uses newsletters and AI content?
The impact depends on how much AI you already use and how you communicate with your audience. Here are three typical situations with recommended actions.
Illustrative examples: the numbers and situations are meant to show the reasoning, they are not real customer data.
| Company type | Current use of AI | Risk without a policy | Recommended action |
|---|---|---|---|
| Professional firm (accountant, lawyer) | Monthly newsletter drafted with AI support | Content classified as AI-generated on matters of public interest: AI Act risk | Add a voluntary label + certified human review |
| B2C e-commerce | Product pages and promotional emails generated with AI | Negative brand perception if customers discover AI use without disclosure | Explicit AI policy in your communications, label on automated content |
| B2B manufacturing company | Technical newsletter written entirely by human experts | No regulatory risk, but a missed opportunity to stand out | Explicitly communicate human authorship as added value |
What tools and approaches exist to manage AI transparency in content?
There are three main approaches: voluntary disclosure, automatic detectors like Pangram, and internal editorial policies. The best solution often combines them.
| Approach | How it works | Pros | Cons |
|---|---|---|---|
| Voluntary label (Substack) | The creator declares AI use before publishing | Direct control, protects against misclassification | Requires internal discipline and a clear policy |
| Automatic detection (Pangram) | Software analyzes the text and estimates the AI share | Objective, requires no action from the creator | Not foolproof: formal texts can be misclassified |
| Internal editorial policy | The company sets rules on when and how to use AI | Scalable, consistent with the brand | Requires team training and periodic updates |
| Certified human review | Every AI-assisted piece is reviewed and signed off by an expert | Maximum credibility, AI Act compliant | Slower and more expensive, best for high-risk content |
The right choice depends on your content volume, industry and audience. For a chain of stores sending promotional newsletters, a standard label and an internal policy are enough. For a law firm publishing regulatory analysis, certified human review is almost a must, including for AI Act compliance.
It's also worth looking at how other channels are evolving: the issue of digital content credibility also touches on the fight against content theft that X and Grok are facing, and more broadly on how platforms are redefining the rules of the game for creators.
What real risks do you run if you ignore this trend?
There are three risks: regulatory (AI Act), reputational (loss of trust) and competitive (those who are transparent stand out). Ignoring them won't make them go away.
Regulatory risk is the most immediate: Article 50 of the AI Act already applies. But reputational risk has the longest-lasting effects.
The Edelman Trust Barometer 2026 shows that nearly 7 in 10 people fear being deceived by institutional leaders. In this climate, a brand caught using AI in its content without disclosing it, even unintentionally, can suffer credibility damage that is hard to recover from.
| Risk | Probability | Impact | How to mitigate |
|---|---|---|---|
| AI Act penalty for failure to disclose | Medium (depends on industry and content) | High (up to €15M or 3% of turnover) | Internal policy + labels on AI content |
| Loss of audience trust | High (the perception gap is already documented) | High (hard to recover from) | Proactive, transparent communication about AI use |
| Misclassification by Pangram | Medium (detectors aren't infallible) | Medium (temporary reputational damage) | Voluntary label before publishing |
| Competitive disadvantage | High (transparent brands stand out) | Medium-high in the medium term | Adopt transparency as your brand positioning |
Where to start: practical steps to manage AI transparency in your communications
Start with an internal audit: understand where and how you already use AI in your content, then define a policy and communicate it. Five steps, in order.
- 1 · Marketing manager / Content leadAudit your current AI useMap all content produced with AI support: newsletters, social posts, product pages, press releases. Distinguish between AI-generated (written by AI) and AI-assisted (reviewed by humans).
- 2 · Management / LegalCheck AI Act complianceIdentify which content falls under Article 50 (topics of public interest). Consult a lawyer if you operate in a regulated sector.
- 3 · Marketing managerDefine your AI editorial policySet clear rules: when AI is used, who reviews, how content is labeled. The policy must be written down and shared with the whole team.
- 4 · Content teamAdd voluntary labelsOn Substack and other platforms that allow it, add the AI label before publishing. It's the simplest way to protect yourself from misclassification.
- 5 · Marketing managerCommunicate the policy to your audienceAdd a note about your AI policy in your newsletter, on your website, or on your 'About us' page. Proactive transparency builds trust instead of eroding it.
What mistakes are made most often when tackling this topic?
The most common mistake is waiting for the problem to show up instead of defining a policy first. The second is treating disclosure as a bureaucratic obligation rather than a brand lever.
Many Italian companies are already using AI in their content, often without an explicit policy. This creates three typical problems:
- Internal inconsistency: every team member uses AI differently, with no shared rules on review and disclosure.
- Reacting instead of planning: you act only when a complaint or a wrong classification arrives, instead of preventing it.
- Disclosure as an excuse: you add an AI label without caring about content quality, losing the competitive advantage of transparency.
A less obvious mistake: believing disclosure hurts the brand. IAB data shows that 72% of marketers want an industry standard, which means transparency is becoming the expected norm, not the exception.
Video and multimedia content are affected too: as we saw when analyzing YouTube's changes to view counting, platforms are redefining credibility metrics across all formats.
How can you tell whether your AI policy is really working?
Three indicators to monitor: newsletter open rate, qualitative reader feedback, and the absence of misclassifications by automated detectors.
| Indicator | How to measure it | Alert threshold |
|---|---|---|
| Newsletter open rate | Email platform (e.g. Substack, Mailchimp) | Below 25%: check whether perceived authenticity has dropped |
| Unsubscribe rate | Email platform | Spike after introducing AI content: a sign of misalignment with your audience |
| Qualitative feedback | Email replies, comments, surveys | Questions about content authenticity: a sign the policy isn't communicated clearly |
| Pangram classifications | Substack tool (for those using the platform) | AI-generated classifications on human-written content: review your style and add a voluntary label |
| AI-related brand mentions | Social and media monitoring | Negative mentions tied to disclosure: act through proactive communication |
So, is AI transparency really worth it for your company?
It's worth it if you already use AI in your content (even just for drafts or editing), publish newsletters or content on regulated topics, or want to stand out from competitors with more authentic communication.
A middle path: you use AI only for internal (unpublished) work and don't operate in high-regulatory-risk sectors. You can wait a few months, but prepare your policy now.
Not yet if you produce all your content entirely without AI and have no plans to introduce it. Still, keep an eye on how standards evolve, because the market moves fast.

How we see it at SHM
For us, AI transparency isn't a compliance issue: it's about respect for the people who read. We believe AI should be integrated to free companies from routine, not to replace human ingenuity or to produce content nobody has really thought through.
When we work with companies on strategic AI integration, the first step is always defining where AI adds real value and where it risks eroding the relationship with your audience. Disclosure isn't a cost: it's the signature of someone who still has something to say.
If you want to understand how to structure an AI policy for your content, or how to position your brand in the new ecosystem of Marketing and performance ADV, we're available for a concrete conversation. You can also learn how to optimize your presence for AI search engines with our SEO for AI service, or train your team with our AI training for companies program.
Content credibility also touches visual marketing: if you're considering how to use AI to produce images, read our analysis of Adobe AI Critique and visual marketing.

Frequently Asked Questions
Pangram is available to anyone using Substack: both readers and creators can request a scan of a piece of content. The result is visible only to the user who started the analysis, not to the general public. It only works on content published after July 2026.
It depends on the level of intervention. Light editing (spell-checking, synonyms) is generally considered AI-assisted and doesn't require explicit disclosure. If AI generated entire paragraphs or structured the content, disclosure is recommended, and in some cases mandatory under the EU AI Act if the topic is of public interest.
Yes, Article 50 applies to all operators who publish AI-generated content on topics of public interest in the EU, regardless of size. Penalties are proportional to revenue, but the reputational risk is the same for everyone. It's best to consult a lawyer if you operate in a regulated sector.
Substack creators can request removal of the result if they believe the classification is wrong. The best way to prevent this is to add the voluntary label before publishing: that way you control the narrative, not the algorithm.
IAB data shows that 45% of consumers have a positive perception of AI ads, versus the 82% that marketers wrongly estimate. The risk isn't disclosure itself, but undisclosed discovery. Brands that communicate their AI use proactively stand out positively compared to those 'exposed' by a tool like Pangram.
For now, Pangram is specific to Substack, but the signal is about the market: when a platform with 100,000 monetizing publishers adopts a standard, others tend to follow. Beehiiv, LinkedIn Newsletter and traditional email marketing platforms will soon face the same question. Better to prepare now.
AI transparency isn't the problem: it's the answer to the trust problem that was already eroding before.
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