SC-AI-036 · Content and platform

Deepfake and impersonation safeguards

High effortCovered by ISO 27001: New for AISatisfies 14 obligations in 7 policies

What it means

  • Two sides:
    • Do not enable deepfakes: stop your AI tools from creating deceptive likenesses or voices of real people without consent, and detect synthetic content on your platform.
    • Do not be impersonated, and do not impersonate: make it easy for customers to verify that AI communications really come from you, and never pass off AI as human or human as AI.
  • Covers face swaps, voice clones, avatar videos and morphed images.
  • ISO 27001 reuse: None. New for AI, not covered by ISO 27001. Social engineering awareness training under ISO 27001 helps with the staff fraud angle only.

Why it matters

  • The 2026 IT Rules require technical measures against deceptive depictions of real people, 2-hour removal of impersonation content on complaint, and for SSMIs a technical check of uploader SGI declarations.
  • MeitY advisories ask SSMIs to identify and remove reported deepfakes within 36 hours and to protect electoral integrity.
  • RBI FREE-AI asks regulated entities to use only verifiable channels (for example 1601-series numbers for voice, labelled digital interfaces) and never to falsely claim AI use.
  • Voice-clone fraud against Indian bank customers and CXO impersonation scams are rising.

Checklist

  1. If you offer image, video or voice generation: require consent or rights for real-person likenesses; block public figure and candidate likenesses by default.
  2. Use face and voice similarity checks to refuse cloning without verified consent.
  3. Label and embed provenance in all synthetic media (SC-AI-023 Label AI-generated and synthetic content).
  4. SSMIs: deploy deepfake detection tools to verify uploader declarations, proportionate to content type and source; test their accuracy (SC-AI-015 Pre-deployment testing and validation).
  5. Offer a fast reporting route for impersonation victims linked to the 2-hour takedown process (SC-AI-035 Takedown and response timelines).
  6. BFSI: run AI voice and messaging only from registered, verifiable channels (1601-series numbers, verified sender IDs); publish them to customers.
  7. Train staff against deepfake CEO or vendor fraud: call-back verification for payment requests.
  8. Add election-period controls and monitoring (SC-AI-034 Unlawful and prohibited content safeguards).

Evidence examples

  • Consent capture records for voice or face cloning features.
  • Blocked-likeness list and refusal test results.
  • Deepfake detection tool evaluation report (accuracy, false positives).
  • Registered channel list (1601 numbers, sender IDs) and customer communication publishing them.
  • Impersonation report tickets with response times.
  • Staff anti-impersonation training and call-back procedure.

Common pitfalls

  • Consent checkbox with no verification that the uploader is the person in the sample.
  • Detection tool bought and never tested on Indian faces, accents or languages.
  • Bank AI calls from ordinary mobile numbers that customers cannot distinguish from fraudsters.
  • Treating deepfakes only as a content problem and ignoring payment fraud risk.

Satisfies

Standards crosswalk

Clause references only. Check the standard itself for the exact wording.

ISO/IEC 42001

  • A.6.2.4 verification and validation
  • A.9.2 processes for responsible use
  • A.9.4 intended use

ISO/IEC 27001

No direct equivalent

SOC 2

No direct equivalent

Key takeaways

  • Prevent your tools from cloning people without consent, and detect deepfakes on your platform.
  • Make your own AI channels verifiable so customers can spot fakes.
  • Link deepfake reports to the 2-hour takedown clock.

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