Generative AI (GenAI) is rapidly transforming the media ecosystem and the world at large, for better and worse. Documentary filmmaking has been thrown into an existential moment by this new technology, which threatens the very core of the relationship between filmmakers and viewers – one fundamentally built on the belief that what is being presented as truth is in fact true.

We founded the Archival Producers Alliance (APA) as a way for archival producers to come together, share their collective knowledge, and to influence policy and effect change within the industry.  The organization now includes hundreds of experienced producers and researchers across the country as well as internationally.

As professionals who work to research, source, and verify the veracity of archival materials in documentaries, we were concerned when we started seeing GenAI used to create synthetic primary source materials, such as photorealistic images. The APA decided its first initiative would be addressing concerns over the use of GenAI in documentary films.

Seeing the potential for trust to be compromised, the APA developed guidelines that were recently published after launching the Initiative on Generative AI in Documentaries at the Camden Film Festival.

“We created these guidelines as filmmakers passionate about maintaining the impact of the work we do,” the guidelines state. “By entering the conversation at this stage, we hope this document and our organization will bring thoughtfulness and intentionality to the fast-approaching future. We believe that with the integration of standards such as these, documentary programming will continue to be an engaging, reliable, and most of all, trusted form of audiovisual storytelling that records human history and expresses human experience.”

The APA recognized that there are good reasons for documentarians to use AI-generated media: to bring to life the stories of people who are missing from history, or to take viewers to a time or place without adequate visual representation. But without standards, the use of GenAI threatens to distort history and break the trust filmmakers have with audiences. Additionally, generated material presented as “real” in one film can be passed along – on the internet, in other films – and is in danger of forever muddying the historical record.

Filmmakers and executives alike were hungry for guidance on how to use this new, powerful tool.  In response, the APA aimed to craft a set of principles which – in addition to use by filmmakers themselves – could be reflected in documentary funder applications, streamer and broadcaster deliverables, festival and award organization criteria, and production workflows.

The guidelines identify four primary areas for filmmakers to consider when using GenAI: the value of primary sources, transparency, legal considerations, and ethical considerations when using human simulations.

Transparency is at the heart of the document, which includes both inward transparency across the production team and outward transparency with the audience.

For inward transparency, the guidelines suggest adding a temporary watermark to GenAI materials to avoid confusion during the editing process. They also recommend production teams produce cue sheets for all GenAI elements to record prompts used, software version, date created, descriptions, and timecodes.

Regarding outward transparency, the guidelines “strongly advise filmmakers to alert and make clear to audiences their use of GenAI.”  The guidelines “recognize that different types of transparency may be required, depending on context,” but provide various potential methods, such as lower thirds or watermarking, narration, and top of show language.

The PBS Editorial Standards also establish transparency as a core editorial principle: “Transparency is the principle that content should be produced in a way that allows the audience to evaluate the credibility of the work and determine for themselves whether it is trustworthy.”

APA’s work aligns closely with PBS’s standards. PBS published a guidance memo for producers last year that outlines how its core principles apply to this emerging technology.  The guidance says: “The current standards – including the core principles of Editorial Independence, Accuracy, Transparency, and Inclusiveness – empower producers to think critically about any generative AI output, to preserve our fundamental commitment to telling human stories, and to vigilantly safeguard the public’s trust in PBS content.”

The APA guidelines also recommend considering several additional key factors when exploring the potential use of GenAI.  First, we “advise filmmakers to consider the role played by algorithmic bias when using GenAI to create an image—both in reinforcing stereotypes and in overcorrecting to combat them.”  It is essential to keep in mind that “most GenAI models draw from an incomplete version of the historical record, as the majority of physical audiovisual archives still remain undigitized.”

Second, we “encourage filmmakers to treat image generation with the same intentionality, and the same care for accuracy and sensitivity, as they would a traditional re-creation, so that human discernment remains central to the process.”  While the issues posed by GenAI are on a continuum with those long posed by traditional reenactments and re-creations, GenAI output presents a risk of greater magnitude because it requires so little time and expense to create.

To establish these new guidelines, the APA spent months researching existing guidelines, presenting at conferences, and meeting with members, filmmakers, and AI scholars.  The APA’s new Initiative on Generative AI in Documentaries aims to continue helping filmmakers by providing materials such as case studies, sample cue sheets, and crediting guidance in addition to offering workshops and panels at film festivals and conferences.  We believe that the survival of the documentary industry – in all of its power and promise to help us understand and interpret our history and our present – is contingent on maintaining a truthful and transparent relationship with our viewers.

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Stephanie Jenkins, Jennifer Petrucelli, and Rachel Antell are the directors of the Archival Producers Alliance.  Stephanie is a researcher and documentary producer with more than a decade of experience in non-fiction media.  Jennifer and Rachel are Emmy-nominated archival producers whose work has appeared on PBS as well as most of the major streaming and broadcast outlets.