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Use AI to draft marketing email, not to approve it. Before a campaign is sent, a named human should check its claims, audience, personalization, links, and applicable email requirements; record approval of the final version; and monitor the send for problems. The workflow below adapts NIST’s voluntary AI risk-management guidance to email production. It is not a legal safe harbor, and the U.S. compliance details apply to U.S. commercial email.
1. Set the rules before anyone drafts
Decide which AI tools and marketing uses are approved, who owns the workflow, what customer or confidential information may be entered, and which questions require specialist review. Put the rules in writing so staff know when to use AI, what information to keep out of prompts, and when to stop and escalate.
NIST’s Generative AI Profile identifies governance, data protection and retention, acceptable-use policies, impact assessment, risk-based controls, and ongoing monitoring as relevant considerations. Its AI guidance is voluntary; organizations can scale controls to their needs and risks.
2. Keep the brief with the draft
A reviewer cannot reliably assess copy without knowing what it is supposed to do. Keep a campaign brief alongside the AI-generated draft, including:
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- Intended audience and campaign purpose.
- Offer terms, dates, and current product or service details.
- Factual and comparative claims, with the evidence approved to support them.
- Required disclosures, destination links, and intended call to action.
If available, record which AI tool and version produced the draft. NIST recommends documenting system context and output limitations, as well as tracking and documenting AI use. These details help a reviewer understand what they are assessing; they do not establish that the draft is accurate.
3. Assign a person who can stop the send
Name a marketing reviewer with authority to edit, reject, or hold the email. Send questions beyond that person’s remit to the relevant specialist—for example, legal for a compliance issue, privacy for a data-use question, or product for a technical claim. Record who owns each decision and how a draft reaches them.
NIST’s AI Risk Management Framework Core calls for policies that distinguish human and AI responsibilities and for documentation that supports transparency, human review, and accountability. A review gate works only if no one can bypass it by editing or scheduling an unapproved version.
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4. Review the email in layers
Check fit with the brief and audience
Confirm that the message serves the stated purpose, addresses the intended audience, and accurately reflects the offer and current terms. Check whether the tone and level of detail suit the recipients rather than merely sounding polished.
Verify every material claim
Check each factual, comparative, performance, price, discount, and deadline claim against approved evidence and current terms. A plausible-sounding statement is not substantiation. Remove or correct claims that cannot be verified, and route disputed or high-impact claims to the appropriate specialist.
Inspect personalization and data use
Check that personalization is appropriate for the recipient and does not reveal information they should not see. Confirm that data used in the prompt and email fits the organization’s approved workflow. Escalate unexpected or sensitive personalization rather than assuming it is harmless because it appears in a draft.
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Test links and the requested action
Open each link and confirm that it leads to the intended, current page. Check that the landing page matches the email’s offer and claims, and that the call to action is clear and works as intended.
5. Run the email checks that apply
For U.S. commercial email, the FTC’s CAN-SPAM compliance guide says messages must use accurate routing information and non-deceptive subject lines, identify advertising as required, include a valid physical postal address, and provide a clear way to opt out. Opt-out requests must be honored within 10 business days, and the mechanism must be able to process requests for at least 30 days after sending, according to the FTC guide checked October 4, 2026.
The Act is not limited to bulk email: FTC guidance says it covers commercial messages whose primary purpose is advertising or promotion, including business-to-business messages. For a message that mixes transactional and promotional content, do not classify it based only on an existing customer relationship. The primary purpose controls; the subject line and whether transactional content appears mainly at the beginning can affect that assessment.
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Using an email service provider does not remove responsibility. The FTC says both the company whose product is promoted and the company that sends the email may be responsible. Keep a named sender-side approver even when a vendor handles delivery. These are general U.S. points, not a determination of what applies to every message or recipient; check applicable requirements for the campaign’s circumstances and jurisdictions.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.6. Approve and preserve the exact final version
After revisions, make sure the version being scheduled is the one the reviewer approved. Preserve a record that lets the team trace the decision:
- Final email copy and campaign identifier.
- Reviewer and approval time.
- Substantive changes made during review.
- Links to claim substantiation or specialist decisions, where relevant.
Prevent later edits from silently bypassing the review gate: material changes after approval need review before the send. NIST notes that documentation can improve human review and accountability.
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After sending, provide a clear route for reporting and handling problems. Look for incorrect claims, broken links, unexpected personalization, complaints, and failures to process opt-outs. Use incidents and recurring issues to update templates, reviewer guidance, risk tiers, and tool-use rules. NIST treats AI governance and risk management as ongoing and iterative, rather than a one-time approval.
How much review does a campaign need?
Apply deeper review when an error could have greater impact or be harder to correct. Consider the evidence burden for claims, audience sensitivity, data exposure, offer complexity, and whether a sent message can be reversed or corrected. A routine, low-impact draft may need a simpler check; a message involving sensitive personalization, consequential claims, or complex terms calls for specialist attention and a stronger record. NIST supports risk-based oversight, but does not prescribe a specific email review tier or guarantee a particular outcome.
Pre-send checklist
- Is a named person accountable for approving this campaign?
- Does the draft match the brief, intended audience, offer, and current terms?
- Can every material factual or comparative claim be substantiated?
- Are personalization and data use appropriate and approved?
- Are sender details, subject line, disclosures, postal address, links, and opt-out method correct for the message and jurisdiction?
- Is the exact final version identifiable, with later changes routed back for review?
- Can the team trace who approved what and when?
- Is there a post-send path to report and address errors?
What this workflow can—and cannot—do
Human review gives the organization a release gate, a record of decisions, and a way to catch issues before sending. It cannot guarantee that every claim is accurate, that a campaign complies with every applicable law, or that results will improve. NIST’s AI Risk Management Framework is voluntary guidance; email obligations depend on the message and applicable jurisdiction.
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