Cannes Lions’ response to the DM9 scandal rests on a specific theory of institutional failure, and it is worth naming before evaluating whether the response is likely to work.
The theory goes like this: the problem was that the wrong people were accountable. Junior teams made submissions that senior leaders had not scrutinized. If the CEO and CMO are required to put their names on every entry, they will scrutinize what they’re signing, and fraudulent submissions will be caught before they’re submitted. The rule addresses a gap in oversight. Close the gap, solve the problem.
This theory is coherent and, in limited respects, accurate. What it is not is sufficient. The DM9 submission — a campaign for the Consul brand that used AI-manipulated footage from a CNN Brasil broadcast to simulate a campaign that had not run as presented — did not happen because no one senior was paying attention. It happened because someone decided that winning was worth the risk of fabricating evidence for it. Adding a signature requirement to that decision does not make the decision less likely. It makes the decision more expensive if discovered, which is a different thing.
What the rule actually does
The new Cannes Lions integrity standards, announced after the 2025 festival, require that every entry be personally attested by the business leader of the submitting agency and a senior marketer from the brand. The festival has also introduced AI-detection tools, an Integrity Council for escalated cases, and the possibility of three-year bans for agencies found to have submitted deliberately misleading work.
The CEO and CMO sign-off is the most discussed element, and it does change the incentive structure in a specific and real way. Under the previous system, the person who decided to fabricate case study materials was unlikely to be the person who suffered the most severe consequences if the fabrication was discovered. The sign-off requirement moves liability upward, making agency leadership personally accountable for the integrity of every submission bearing their name. This is a form of accountability, and it is meaningfully different from what existed before.
What it is not is a test of whether the work actually ran. An agency CEO who is willing to authorize fabricated campaign materials — who has decided that a Grand Prix is worth the risk of deception — will sign the form confirming the materials are authentic with approximately the same ease as an account director. The signature is not a verification mechanism. It is a liability assignment. And liability assignment changes behavior most reliably in people who were not planning to commit fraud; for people who were, it primarily changes the distribution of consequences if they’re caught.
The fraud economy the rule leaves intact
The question the CEO/CMO sign-off requirement does not answer — and that the broader package of new rules only partially addresses — is why the fraud happened in the first place. The incentive is well understood: Cannes Lions awards carry substantial commercial value in the form of new business pitches won, talent recruited, and client confidence maintained. A Grand Prix is not just a trophy. It is evidence, in the market for agency services, that a firm’s creative output meets one of the highest available standards of creative excellence.
This evidence is used in competitive pitches, in fee negotiations, and in conversations with the clients whose spending sustains the agency. The award is worth money, directly and repeatably, well beyond the festival at which it is won.
Ghost campaigns — entries that represent work that was never run, or was run in a form significantly different from what the submission presents — are not a new phenomenon. Industry insiders have discussed the practice informally for years, and the DM9 case is better understood as the most visible recent instance of a persistent pattern than as an aberration. What AI did was lower the production cost of plausible fabricated evidence to near zero. Before generative tools, constructing a convincing case study for a campaign that hadn’t run required significant effort: staged photographs, constructed media schedules, invented metrics that required detailed crafting to withstand scrutiny. The effort was a friction that deterred some fraction of those who might otherwise have attempted it. AI removed that friction without removing the incentive.
The CEO/CMO sign-off requirement addresses neither of these things. It doesn’t reduce the commercial value of a fraudulently obtained Grand Prix. It doesn’t make fabricated evidence harder to construct. It adds a procedural step to the submission process and assigns personal liability to the people whose names appear on it. This is governance, and governance has a role. But governance is a response to the symptom — a submission was fraudulent — rather than to the cause — an industry decided that awards were worth fabricating.
What honest accountability would require
The harder question, which the new rules do not attempt to answer, is whether the industry is willing to examine the awards culture that made the fraud economy possible. Cannes Lions is not simply a celebration of creative work. For many agencies, particularly those outside the major English-language markets, it is a commercial lifeline — the primary mechanism through which creative quality is credentialed in a global market that has no other common standard. The pressure to win is proportionate to the commercial stakes attached to winning, and those stakes are set by the clients and procurement teams that use Cannes results as a proxy for creative quality when evaluating agencies.
An industry that genuinely wanted to address the fraud economy would look at that dynamic and ask whether it should change. Should Cannes Lions results carry the commercial weight they currently do in pitch processes? Should clients and procurement teams treat award credentials as less determinative, given that they’ve now established a public record of being falsified? Should the festival itself reduce the number of awards categories, limiting the supply of credentialing hardware and therefore reducing the pressure associated with any single entry?
These are questions about culture and incentive, and they are substantially harder than requiring a signature. They require the industry to decide that the problem is not a governance gap but a values problem — that the fraud happened not because no one senior was watching but because the rewards for winning had grown disproportionate to the integrity required to win honestly. That conclusion requires more discomfort than a form.
The paperwork vs. the practice
The agencies quoted in the trade press describing the new rules as “burdensome but necessary” are being honest about both adjectives. The rules are burdensome: gathering senior sign-offs across agencies and client organizations, meeting new documentation requirements, navigating fact-checking processes, is real work added to an already elaborate submission process. And they are necessary, in the sense that some response to a public fraud of this magnitude was inevitable and doing nothing would have been more damaging than doing something.
But “burdensome but necessary” is a framing that locates the solution in compliance — in doing the required paperwork — rather than in the practice the paperwork is meant to enforce. The agencies that submitted fabricated work in 2025 did not do so because the submission process was too light. They did so because they concluded that the risk of fraud was acceptable relative to the reward of winning. New documentation requirements do not obviously change that calculation for the minority of agencies willing to make it.
What might change it, over time, is a consistent pattern of detection and enforcement — the three-year ban prospect being taken seriously, the Integrity Council operating with genuine independence, the AI-detection tools improving in capability and coverage. If the expected cost of fraud rises substantially and demonstrably, the risk-reward calculation changes. Rules alone don’t produce that outcome. Rules enforced, consistently and publicly, might.
Cannes Lions has introduced the rules. The question the industry should be watching is whether the enforcement that gives them meaning materializes. Bureaucracy without consequence is a form of theater — a visible response to a problem that leaves the problem’s underlying structure intact. The CEO and CMO who sign every entry will, for the most part, be signing work that was real. The small minority for whom the signature is a lie will not be stopped by the form. They’ll be stopped, if they’re stopped at all, by whether the festival has actually built the capacity to find out.
