When the Bots Write Your Annual Report: Who’s Legally Responsible?

AI can translate words. Only humans can translate responsibility.

By Steve Yolen

The world’s largest corporations are quietly using artificial intelligence to help translate their annual reports, sustainability statements, and investor communications. It saves time and money. But it also introduces a question no boardroom wants to confront: when AI mistranslates a key passage, who takes the blame?

AI tools like ChatGPT and DeepL now produce elegant, grammatically flawless English versions of Portuguese or Spanish reports in seconds. But behind the surface fluency lies a potential compliance trap. These systems don’t certify accuracy, assume no liability, and often make subtle errors that only a human expert would catch.

The legal fine print

For publicly traded companies, every translated report is more than communication—it’s a legal document. In Brazil, the CVM requires all investor-facing information to reflect the original meaning of the Portuguese version. In the U.S., the SEC and FASB rules similarly demand faithful, transparent disclosures. In Europe, the ESMA has issued guidelines that make inaccurate translations a compliance violation.

An AI system cannot sign off on that responsibility. Yet many communications and investor-relations teams treat AI-generated English drafts as final copy. The result is an emerging gray zone where errors in translation could expose a company to regulatory or reputational risk—without any clear chain of accountability.

When “close enough” becomes misleading

A typical mistake may seem small: an AI translator confuses “net revenue” with “gross revenue,” or turns a sentence about “potential liabilities” into one about “existing liabilities.” To a financial analyst or investor, the meaning changes drastically.

In sustainability and ESG reports, tone can be even more critical. A statement like “the company seeks to reduce emissions intensity” may become “the company will reduce emissions,” implying a promise rather than an aspiration. Such shifts can have legal and brand consequences.

The case for the human guarantor

That’s why forward-looking firms are reinstating a crucial role in the process: the human guarantor—an experienced translator-editor who validates every line before publication. This isn’t about rewriting the entire text; it’s about confirming that AI didn’t alter meaning, tone, or regulatory context.

Translation bureaus that understand both language and corporate governance are becoming part of the compliance chain. Their job is not just linguistic, but fiduciary: to ensure the English text would hold up under regulatory scrutiny if challenged.

Technology with accountability

The new gold standard is a hybrid workflow:

1. AI performs the initial draft.

2. A human expert validates the result, ensuring semantic, cultural, and financial accuracy.

3. The bureau certifies or signs off the translation for corporate filing.

That last step—human certification—is what protects the company’s credibility. Because ultimately, investors don’t care who translated the report; they care whether they can trust it.

The translation of trust

AI will continue to reshape workflows, but trust cannot be automated. When it comes to the words that move markets, only a human can stand behind them.