Policy on AI-Generated, Computationally Manipulated, and Falsified Evidence in External Submissions

 

v1.0  |  May 2026

Document Owner: Head of IT

 

 

Document Control

 

Document Control
Document Title	Policy on AI-Generated, Computationally Manipulated, and Falsified Evidence in External Submissions
Document Reference	FCY-GOV-POL-001
Document Type	Policy
Version	v1.0
Status	Active
Classification	Internal
Service Area	Cross-Service (Planning, Building Control, Licensing, Enforcement, Legal)
CAF Control Area	N/A
Document Owner	Head of IT
Approval Authority	Service Director for Corporate Resources
Review Cycle	Annual
Date of Issue	May 2026
Next Review Date	July 2027
AI Applicable	Yes
DPIA Required	No
LGR / Data Sharing	Digital Transformation Planning

 

Version History

 

Version	Date	Author (Post)	Approved By	Summary of Changes
v1.0	May 2026	Head of IT	Service Director for Corporate Resources	Initial issue. Policy developed in response to operational experience of AI-generated and computationally manipulated evidence submitted in external applications and regulatory proceedings. First council policy of this type.

 

 

Roles and Responsibilities

The following posts hold responsibilities under this policy. Post names are used throughout; personal names are not recorded in policy documents.

 

Role / Post	Responsibilities
Head of IT	Policy owner. Provides technical guidance to service areas on detection methods, tools, and emerging AI capabilities relevant to evidence falsification. Coordinates with ICT and Digital on any technical investigation support required.
Service Director for Corporate Resources	Approves this policy. Receives escalations involving confirmed or strongly suspected falsification. Authorises referral to the police and legal counsel.
Head of Planning	Responsible for implementing this policy within Planning and Development Management. Ensures officers are trained to identify indicators of AI-generated or manipulated photographic and documentary evidence in planning applications and appeals.
Head of Building Control	Responsible for implementing this policy within Building Control. Ensures that site inspection photography and compliance documentation submitted in lieu of physical inspections is subject to verification checks. The operational trigger for this policy.
Licensing Manager	Responsible for implementing this policy within Licensing. Ensures that photographic and documentary evidence submitted in support of licence applications and representations is subject to appropriate scrutiny.
Legal Services	Advises on the legal consequences of confirmed falsification, prepares referrals to the police, and manages any proceedings arising from fraudulent submissions. Advises on the evidential standards required to sustain enforcement action.
All Decision-Making Officers	Responsible for applying the verification checks defined in this policy when assessing evidence submitted with external applications, representations, or regulatory proceedings. Must escalate suspected falsification in accordance with this policy.

 

 

1. Purpose

This policy establishes Fylde Council’s position on, and response to, the submission of artificially generated, computationally manipulated, post-processed, or otherwise falsified photographic, video, or documentary evidence in external applications, representations, appeals, and regulatory proceedings.

The rapid advancement and increasing accessibility of generative artificial intelligence tools, including large image generation models, video synthesis tools, and AI-assisted document drafting, has materially lowered the barrier to producing convincing but entirely fabricated evidence. The Council has direct operational experience of submissions where photographic evidence is suspected to have been generated or altered using such tools rather than captured at the actual site or location claimed.

This policy does not presume dishonesty on the part of applicants or agents. It establishes the framework within which officers assess, verify, and respond to evidence that raises legitimate concerns about authenticity, and the process by which confirmed or strongly suspected falsification is escalated and, where appropriate, referred to the police.

2. Scope

This policy applies to all external submissions received by Fylde Council that include photographic, video, or documentary evidence used to support or contest a decision, including:

• Planning applications, pre-application enquiries, and planning appeals.
• Building regulations applications, completion certificates, and compliance documentation, including site inspection photographs submitted in lieu of physical inspections.
• Licensing applications, representations, and licence review proceedings.
• Enforcement investigations and appeals.
• Statutory consultations where evidence is submitted in support of a position.
• Complaints and representations where photographic or documentary evidence is provided to support a claim.
• Any other regulatory or decision-making process in which the Council relies on externally submitted evidence.

 

This policy applies to all officers involved in the receipt, assessment, and determination of the above, regardless of service area.

3. Background and Context

3.1 The Emerging Risk

Until recently, the production of convincing falsified photographs or documents required significant technical skill and was therefore relatively rare. Modern generative AI tools, including text-to-image models, inpainting tools, and large language models capable of drafting professional reports, can be used by individuals without technical expertise to produce evidence that is superficially plausible.

Specific risks the Council has identified or assessed include:

• Photographs of building works or site conditions generated by AI or edited to show a state of completion or compliance that does not exist, submitted in place of genuine site inspection photography.
• Photographs of a site submitted to support a planning application that have been manipulated to remove or add features, alter conditions, or misrepresent the visual impact of a proposal.
• Professional reports, heritage assessments, structural surveys, or ecological surveys generated using AI tools without genuine site investigation, submitted as supporting evidence.
• Falsified compliance certificates, warranty documents, or statutory approvals submitted as part of a building control completion package.
• Video evidence submitted in enforcement or licensing proceedings that has been synthetically generated or materially edited.

3.2 Legal Context

The submission of falsified evidence to a local planning authority, building control body, or licensing authority is a serious matter with potential criminal consequences. The relevant legal framework includes:

• Fraud Act 2006: fraud by false representation (section 2) applies where a person dishonestly makes a false representation with the intent to make a gain or cause a loss. Submitting AI-generated photographs as genuine site evidence may constitute fraud.
• Forgery and Counterfeiting Act 1981: the making of a false instrument (section 1) applies where a document is falsified with the intention that it be used to induce another person to accept it as genuine. Fabricated certificates or falsified professional reports may fall within this provision.
• Town and Country Planning Act 1990, section 65: it is a criminal offence to knowingly or recklessly make a false or misleading statement in connection with a planning application.
• Building Safety Act 2022: imposes enhanced duties of competence and honesty on those submitting information to building control bodies, particularly for higher-risk buildings. False statements in building control submissions may attract criminal liability under the Act.
• Perjury Act 1911: false statements made on oath or in a statutory declaration carry criminal liability.
• Computer Misuse Act 1990: may apply where AI tools are used in conjunction with unauthorised access to systems to obtain or manipulate data.

4. General Verification Principles

Officers are not expected to be forensic specialists. This policy does not require technical expertise in AI detection. What it does require is that officers apply reasonable professional judgement, that they are alert to the indicators set out in Section 5, and that they escalate promptly when concerns arise rather than proceeding to determination on the basis of evidence whose authenticity is in doubt.

The following general principles apply to all submissions involving photographic or documentary evidence:

• Evidence should be consistent. Photographs submitted together should be internally consistent in terms of lighting, weather, season, site conditions, and the presence or absence of site features. Inconsistency across a submission is a material indicator of concern.
• Evidence should be corroborable. Genuine site photographs can generally be corroborated against aerial imagery, street-level imagery, neighbouring properties, or previous records. Where evidence cannot be corroborated by any independent source, further verification should be sought.
• Metadata matters. Digital photographs and documents contain metadata that records the device, date, time, location, and, in the case of documents, the software used and modification history. Absent, incomplete, or inconsistent metadata is a legitimate basis for requesting further information.
• Professional documentation should be verifiable. Reports and certificates produced by professionals should be traceable to a named individual with verifiable registration in the relevant professional body. Where this cannot be confirmed, the document should not be accepted at face value.
• The burden of demonstrating authenticity rests with the submitter. If an officer has reasonable grounds to question the authenticity of submitted evidence, it is appropriate to request original files, additional verification, or a physical site inspection. The Council is not required to proceed on the basis of evidence it cannot verify.

5. Indicators of Falsification and Detection Approaches

The following table sets out the common indicators of AI-generated or manipulated evidence by evidence type, together with the primary detection approach officers should apply.

 

Evidence Type	Common Indicators of Falsification	Detection Approach
AI-generated photographs	Unnatural lighting or shadows inconsistent with time of day or season. Architectural features that do not match known site characteristics. Background elements that are blurred, distorted, or repeat in a pattern. Absence of expected site features (scaffolding, skips, signage, adjacent properties). Metadata absent or inconsistent with the claimed date and time of capture.	Cross-reference with aerial imagery (Google Maps, Bing, or Council GIS). Check EXIF metadata for device, timestamp, and GPS data. Request original unprocessed files. Compare with previous application photographs or known site records. Request a physical site inspection.
Post-processed or digitally altered photographs	Inconsistencies in pixel density or compression artefacts at boundaries of edited areas. Evidence of cloning or patching (repeating texture patterns). Colours or lighting that change abruptly between areas of an image. Objects or features removed or added that are inconsistent with other images of the same site. EXIF data showing editing software use or a modification timestamp later than the capture timestamp.	EXIF metadata analysis including software field. Request original RAW or uncompressed files. Compare with other photographs from the same submission and previous records. Use image forensics tools to detect cloning or splicing artefacts.
AI-generated documents and reports	Generic or non-specific content that does not reference the actual site, address, or application in sufficient detail. Inconsistencies between the document and other submitted materials. References to standards, legislation, or guidance that do not exist or are incorrectly cited. Lack of professional registration details, signatory credentials, or firm identity. Formatting inconsistencies suggesting assembly from template fragments.	Verify professional credentials of signatories against relevant registers (RICS, RIBA, CABE, relevant professional bodies). Cross-reference specific claims against other submitted documents and known site records. Request original source data or survey records underlying the report. Contact the purported author to confirm authorship.
Falsified compliance certificates and statutory documents	Certificate or document not traceable to the issuing body. Reference numbers that do not conform to the format used by the relevant authority or certification body. Names of certifiers not registered with the relevant scheme. Inconsistencies in font, layout, or logo compared with genuine examples.	Verify directly with the issuing body or certification scheme. Cross-reference reference numbers against scheme databases where publicly available. Contact the purported certifier by an independently obtained number, not a number provided in the submission.
Synthetic or manipulated video evidence	Inconsistent lighting or shadow movement. Unnatural movement of people, vehicles, or environmental elements. Faces or number plates that are blurred, distorted, or absent where they would be expected. Temporal inconsistencies (clock faces, seasonal indicators, passing vehicles inconsistent with the claimed date or time).	Request original uncompressed video files with metadata. Cross-reference with independently obtained CCTV or third-party footage for the same location and time period. Consult with the Head of IT for technical analysis support.

 

This table is not exhaustive. AI technology is developing rapidly and new indicators will emerge. Officers should apply professional judgement and consult the Head of IT where they encounter concerns that are not clearly addressed by this framework.

6. Process for Handling Suspected Falsification

6.1 Initial Concern

Where an officer identifies indicators of potential falsification, they should:

1. Document the specific concern in writing, describing the indicator or indicators that have given rise to it, before taking any further action.
2. Not proceed to determine the application or make a decision that relies on the evidence in question.
3. Notify their line manager and the relevant Head of Service of the concern on the same working day.
4. Where technical assistance is required, contact the Head of IT.

6.2 Verification Step

The officer, in consultation with their line manager, will determine the appropriate verification approach from the following options:

• Request original unprocessed photographic files (RAW format or full-resolution JPEG with EXIF intact) from the applicant or agent.
• Request a physical site inspection, either conducted by a Council officer or by the applicant’s professional adviser under an agreed inspection protocol.
• Cross-reference submitted imagery against aerial or street-level imagery from independent sources, including the Council’s own GIS systems.
• Verify professional credentials of the author of any report or certificate against the relevant professional body register.
• Contact the purported author of a document directly using independently obtained contact details to confirm authorship.
• Consult the Head of IT for technical metadata analysis or AI detection tool assessment where the above steps are inconclusive.

6.3 Outcome of Verification

Following verification, one of three outcomes applies:

• Evidence confirmed as authentic: proceed with the determination in the normal way. Document the verification steps taken and the basis for the conclusion.
• Evidence cannot be verified but concerns are not confirmed: seek further information from the applicant. If the applicant fails to provide satisfactory further information within a reasonable period, treat the evidence as unreliable and proceed accordingly. Document the position.
• Falsification confirmed or strongly suspected: escalate in accordance with Section 7.

7. Consequences and Escalation

The following table sets out the consequences of confirmed or strongly suspected falsification at each stage of a regulatory process.

 

Finding	Consequence
Suspected falsification identified during assessment	Officer pauses determination and escalates to line manager and Head of Service. Verification checks initiated. Applicant or agent notified that further information is required. Application clock may be suspended pending receipt of verified evidence where permitted under the relevant statutory procedure.
Confirmed falsification prior to determination	Application invalidated or refused. Applicant and agent formally notified of the finding in writing. Matter referred to Legal Services for advice on referral to the police. Record created in the Council’s case management system. Agent or professional may be referred to their regulatory body.
Falsification discovered post-determination	Legal Services instructed immediately. Enforcement action considered in accordance with the relevant statutory regime (planning enforcement, building control, licensing review). Referral to the police for investigation of fraud or forgery. Any consent, approval, or licence granted on the basis of falsified evidence reviewed for revocation.
Referral to the police	Legal Services prepares the referral in coordination with the relevant Head of Service and the Head of IT where technical evidence is required. All digital evidence preserved and documented in accordance with Section 8 of this policy. The Council will cooperate fully with any police investigation.

 

Where an agent or professional adviser is implicated in the submission of falsified evidence, the Head of Service will consider referral to the relevant professional body (for example the Royal Institution of Chartered Surveyors, the Royal Institute of British Architects, or the Chartered Institute of Building) in addition to any police referral.

8. Evidence Preservation

Where falsification is confirmed or strongly suspected, all digital evidence must be preserved immediately and handled in a manner that maintains its integrity for potential criminal proceedings or enforcement action. The following steps apply:

• The original submission, including all files and correspondence, must be preserved in its current state. No files should be deleted, moved, or modified.
• The Head of IT must be notified so that any relevant system records, email metadata, or upload logs can be preserved.
• A contemporaneous written record of all actions taken, observations made, and decisions reached must be created and stored alongside the case file.
• Any copies of the evidence made for verification purposes must be clearly labelled as copies and stored separately from the originals.
• Access to the preserved evidence should be restricted to the officers directly involved in the case and Legal Services.

The principles of the ACPO (College of Policing) Digital Evidence Guidelines should be followed where possible to ensure that any evidence gathered is admissible in subsequent proceedings.

9. Communication with Applicants and Agents

Where verification is requested or concerns are raised, communication with the applicant or agent must be carefully managed to avoid compromising any subsequent investigation:

• Initial communication should request further information without disclosing the specific nature of the concern where possible. A request for original files or a site inspection is a routine verification step that does not require the Council to disclose its suspicion at the outset.
• Where the Council has confirmed or strongly suspects falsification and is considering a criminal referral, Legal Services must be consulted before any further communication with the applicant or agent. Premature disclosure of the Council’s findings may prejudice any criminal investigation.
• All communications in a case involving suspected falsification must be in writing and retained on the case file.
• Officers must not conduct informal conversations with applicants or agents about suspected falsification without prior agreement from their Head of Service and Legal Services.

10. Training and Awareness

The Head of IT, in consultation with Heads of Service, will ensure that relevant officers receive awareness training covering:

• The types of AI-generated and manipulated evidence now in circulation and the indicators described in Section 5 of this policy.
• The practical verification steps available to officers without specialist technical expertise.
• The escalation process and the importance of documentation.
• The legal framework and the potential consequences of falsification.

Training will be incorporated into the relevant service induction programmes and refreshed annually or following any significant development in AI-generated evidence capabilities. The Head of IT will maintain a watching brief on developments in AI image and document generation and will update the training and the indicators in Section 5 as required.

11. Relationship with Other Policies and Processes

This policy operates alongside the following Council policies and should be read in conjunction with them:

• ICT Acceptable Use Policy (FCY-ICT-POL-002): governs staff use of AI tools in their own work and is distinct from this policy, which concerns external submissions.
• Artificial Intelligence Acceptable Use Policy (FCY-ICT-POL-029): sets out the standards for staff use of generative AI, including the prohibition on using AI to generate or falsify records.
• Artificial Intelligence Governance Framework (FCY-ICT-POL-030): the Council’s overarching AI governance framework.
• Data Protection and Information Governance Policy (FCY-ICT-POL-019): governs the handling of personal data in connection with any investigation under this policy.
• The Council’s Anti-Fraud and Corruption Policy and Whistleblowing Policy: apply where falsification involves or is connected to suspected fraudulent activity by or in connection with the Council.
• The relevant service-specific procedural guidance for planning, building control, licensing, and enforcement: this policy sets the cross-service framework; service-specific procedures govern the operational steps within each regulatory regime.

12. Review

This policy will be reviewed annually by the Head of IT in consultation with Heads of Service. Given the pace of development in generative AI capabilities, the indicators table in Section 5 will be reviewed and updated at least annually and following any significant development in AI-generated evidence that comes to the Council’s attention through its operational experience or through national guidance from MHCLG, the Planning Inspectorate, or the Health and Safety Executive.

The Head of IT will maintain a log of all cases in which this policy has been invoked, including the nature of the concern, the outcome of verification, and whether a referral was made. This log will be used to inform the annual policy review.

 

 

 

 

References and Further Guidance

The following legislation, standards, and guidance have informed the development of this document:

 

• Fraud Act 2006. legislation.gov.uk.
• Forgery and Counterfeiting Act 1981. legislation.gov.uk.
• Town and Country Planning Act 1990, section 65 – False statements in planning applications. legislation.gov.uk.
• Planning and Compulsory Purchase Act 2004. legislation.gov.uk.
• Building Safety Act 2022. legislation.gov.uk.
• Building Regulations 2010. legislation.gov.uk.
• Perjury Act 1911. legislation.gov.uk.
• Computer Misuse Act 1990. legislation.gov.uk.
• EU AI Act (Regulation (EU) 2024/1689) Article 50 – Transparency obligations for AI-generated content. European Parliament and Council.
• College of Policing: Digital Evidence and Cybercrime Guidelines (2020). https://www.college.police.uk
• NCSC: Deepfakes and Emerging Synthetic Media Threats (2023). https://www.ncsc.gov.uk
• Planning Inspectorate: Evidence in Planning Appeals – Guidance for Parties (2024). https://www.gov.uk/planning-inspectorate
• RICS: Professional Standards and Ethical Practice – Integrity of Reports (2023). https://www.rics.org
• Royal Institute of British Architects: Code of Professional Conduct (2021). https://www.architecture.com
• MHCLG: Planning Practice Guidance – Use of Digital Technology in Planning (2024). https://www.gov.uk
• Health and Safety Executive: Competence Requirements for Building Control (2023). https://www.hse.gov.uk
• ICO: AI and Data Protection – Synthetic Data and Deepfakes (2023). https://ico.org.uk
• Fylde Council: ICT Acceptable Use Policy FCY-ICT-POL-002.
• Fylde Council: Artificial Intelligence Acceptable Use Policy FCY-ICT-POL-029.
• Fylde Council: Artificial Intelligence Governance Framework FCY-ICT-POL-030.
• Fylde Council: Data Protection and Information Governance Policy FCY-ICT-POL-019.