Cannes Lions’ response to the DM9 scandal is based on a particular theory of institutional failure, and it’s worth naming before assessing whether the response will work.
The theory goes like this: the problem was that the wrong people were reporting. Junior teams made presentations that senior leaders did not review. If CEOs and CMOs are required to sign their names on every login, they will scrutinize what they are signing and fraudulent submissions will be caught before they are submitted. The rule closes the gap in control. Close the gap, solve the problem.
This theory is consistent and accurate to a limited extent. Whatever is said is enough. DM9 presentation — a campaign for the used Consul brand AI-manipulated footage from CNN Brasil broadcast Simulating a campaign that didn’t go as it was presented – it didn’t happen because no one big time was paying attention. It happened because someone decided it was worth the risk of fabricating evidence to win. Adding a signature requirement to that decision does not make the decision less likely. If discovered makes the decision more expensive, that’s a different thing.
What the rule actually does
The new Cannes Lions integrity standardsAnnounced after the 2025 festival, each entry requires personal approval by the presenting agency’s business leader and the brand’s chief marketer. The festival also introduced AI detection tools, an Integrity Board for expanded cases, and the possibility of a three-year ban for agencies found to be presenting deliberately misleading work.
CEO and CMO signing is the most discussed element, and it changes the incentive structure in a specific and realistic way. Under the previous system, the person who decided to fabricate case study materials was unlikely to be the one who suffered the most severe consequences if the fabrication was discovered. The signature requirement shifts the responsibility upward and makes agency management personally accountable for the integrity of each submission bearing their name. It is a form of accountability that is significantly different from what existed before.
Not that it’s a test of whether the job really runs. An agency CEO who decides that a Grand Prix is worth the risk of deception and is willing to authorize fictitious campaign materials will sign off on a form certifying the authenticity of the materials with the same ease as an account director. The signature is not a verification mechanism. It is a task of responsibility. And the accountability task most reliably changes the behavior of people who don’t plan to cheat; for people who are, it changes the distribution of outcomes if they are caught in the first place.
The fraud economy remains intact
The question that the CEO/CMO registration requirement does not address, and the broader new package of rules only partially addresses, is why fraud occurs in the first place. The incentive is well understood: the Cannes Lions awards carry significant commercial value in the form of new business deals won, talent recruited and customer trust maintained. The Grand Prix is not just a trophy. It is proof that the firm’s creative output meets one of the highest standards of creative excellence in the agency services market.
This evidence is used in competitive pitches, fee negotiations, and conversations with clients whose expenses support the agency. The award has direct and recurring monetary value well beyond the festival where it is won.
Ghost campaigns – entries that represent work that was never executed or performed in a significantly different form than the presentation presented – are not a new phenomenon. Industry insiders have discussed this practice informally for years, and the DM9 case is better understood as the most visible recent example of a persistent pattern rather than an aberration. What AI did was reduce the cost of producing plausible fabricated evidence to near zero. Before generative tools, building a convincing case study for an unrealized campaign required significant effort: staged photos, constructed media charts, invented metrics that required detailed craftsmanship to stand up to scrutiny. The effort was the friction that deterred some of the people who might otherwise have tried. AI removed this friction without removing the stimulus.
The CEO/CMO check-in requirement does not address any of these. This does not detract from the commercial value of the fraudulently obtained Grand Prix. This does not make it difficult to construct anecdotal evidence. It adds a procedural step to the filing process and assigns personal liability to those whose names appear therein. This is management, and management has a role to play. But management is responding to the symptom—the presentation was bogus, not the cause—an industry decided the rewards were worth the fabrication.
What does honest accountability require?
A more difficult question, which the new rules do not attempt to answer, is whether the industry is ready to examine the reward culture that makes the fraud economy possible. Cannes Lions is not just a celebration of creative work. For many agencies, especially those outside the main English-speaking markets, it’s a commercial lifeline – a key mechanism for validating creative quality in a global market with no other common standard. The pressure to win is proportional to the commercial stakes tied to winning, and these stakes are determined by clients and buying teams who use Cannes results for creative quality when evaluating agencies.
An industry that truly wants to address the fraud economy will look at this dynamic and ask if it needs to change. Should Cannes Lions results carry the commercial weight they currently do in pitch processes? Should customers and procurement teams view award credentials as less determinative now that they have created a public record that they have been tampered with? Should the festival itself reduce the number of award categories, limit the supply of credentialing equipment and therefore reduce the pressure on any entry?
These are questions of culture and passion, and significantly more difficult than asking for a signature. They are calling for the industry to decide that the problem is not a governance gap, but a problem of values—that fraud has occurred not because no one at the top is watching, but because the rewards of winning have grown out of proportion to the integrity required to win honestly. This result requires more concern than form.
Paperwork versus practice
The Agencies report with reference to the trade press is to be honest about both adjectives that characterize the new rules as “burdensome but necessary.” The rules are heavy: gathering high-level signatures between agencies and client organizations, meeting new documentation requirements, and navigating the fact-checking process is real work added to an already prepared submission process. And necessary in the sense that some reaction to a public fraud of this magnitude was inevitable, and doing nothing would be more harmful than doing something.
But the “hard but necessary” solution in practice is a more compliant solution than the one designed to handle the paperwork – a framework that does the required paperwork. Agencies that submitted fictitious work in 2025 did not because the submission process was too light. They did this because they concluded that the risk of cheating was acceptable relative to the reward of winning. The new filing requirements clearly do not change that calculation for the minority of agencies willing to do so.
What could change it over time is a consistent pattern of detection and enforcement – the prospect of a three-year ban being taken seriously, an Integrity Council operating with true independence, and AI detection tools improving in capability and scope. If the expected cost of fraud increases significantly and visibly, the risk-reward calculation changes. Rules alone don’t do that. There can be consistent and clearly enforced rules.
Cannes Lions has introduced the rules. The question for the industry to watch is whether the implementation that makes sense for them will materialize. Inconclusive bureaucracy is a form of theater—a visible response to a problem that leaves the underlying structure of the problem intact. The CEO and CMO who sign off on each entry will, in most cases, be signing off on work that is real. The form of the small minority where the signature is false will not be suspended. If they are stopped at all, they will be stopped because of whether the festival actually creates an opportunity for learning.
