likeness.

Coming soon. Join the waitlist

What is AI likeness licensing?

AI can now produce a convincing video of a person speaking lines they never recorded. That raises an obvious question: if a business wants to use an AI version of a real person in its advertising, how should permission work? AI likeness licensing is one answer. This article explains what it is, what a licence should cover, and why consent has to sit at the centre of it.

The short definition

An AI likeness licence is an agreement in which a real, identifiable person gives permission for their AI-generated appearance (and, where agreed, their voice) to be used for a defined purpose, usually in exchange for payment.

The key word is defined. A licence is not a sale of someone’s identity, and it is not unlimited permission to recreate them. A well-written licence says what can be made, for whom, where it can appear and for how long. Anything outside those limits is not licensed.

How it differs from a normal photo or talent agreement

Traditional talent agreements usually cover footage of a person that was actually recorded. They can still be complex, but the material is fixed: the person was on set, said those words and was filmed.

With AI, the material is new each time. Once a system has learned how a person looks or sounds, it can generate scenes that never happened. So the agreement has to cover future content that does not exist yet, which makes the boundaries far more important.

Some lawmakers have already focused on this. In California, a contract clause that lets a digital replica of a person’s voice or likeness replace work they would otherwise have done in person can be unenforceable unless it includes “a reasonably specific description of the intended uses” and the person had legal or union representation (California AB 2602, 2024). New York passed a similar rule in 2024 (New York S7676B). These laws apply in those states, but they show the direction of travel: vague, open-ended permission is not good enough.

What a good AI likeness licence covers

There is no single standard form yet, but a fair licence should answer these questions clearly:

  • Who is licensing what? The person (or their verified representative), and exactly which elements: face, body, voice, or a combination.
  • Which brand and which product? Permission for one brand is not permission for its competitors or its parent company’s other products.
  • What kind of script? There is a big difference between a spokesperson reading a script about a product and a personal testimonial (“I use this every day”). A testimonial is an endorsement, and it should need separate, explicit approval.
  • Where will it appear? Placements such as social ads, a website, connected TV, or print.
  • Which countries? Rules on advertising and personal data differ between countries, and so does the person’s comfort level.
  • For how long? A start date, an end date and what happens at renewal.
  • What is off-limits? Categories the person never wants to be associated with, plus categories that should be blocked regardless, such as political messaging or adult content.
  • How is the person paid? For example, a fee each time a licence is issued or renewed, rather than a vague promise of exposure.
  • What does the business receive? Ideally the finished, approved video, not the underlying model, raw recordings or a reusable voice clone that could be used again without permission.
  • How can the person stop future use? Pausing or ending new licences, and what happens to content already published under an earlier licence.

A licence is only as good as the consent behind it. Two practical safeguards matter most.

Verifying the person. Before anyone’s likeness is captured, the platform or business should confirm the person is a real adult who is who they say they are, and that anyone acting for them (a manager or agent) actually has written authority to do so.

Treating face and voice data carefully. Facial and voice data used to recognise or verify someone is especially sensitive. In Australia, the privacy regulator explains that biometric information, “including facial images, when used for automated verification or identification purposes”, is sensitive information under the Privacy Act (OAIC). In the UK, the regulator treats biometric data as special category data when it is used to uniquely identify someone (ICO). Either way, capture data needs strong protection and a clear purpose.

Disclosure: telling viewers it’s AI

Even with full consent, audiences should not be misled about what they are watching. Several platforms already require disclosure. For example, YouTube asks creators to disclose realistic altered or synthetic content, including content that “makes a real person appear to say or do something they didn’t do” (YouTube Help).

In the European Union, the AI Act requires people who use AI to create deepfakes to disclose that the content has been artificially generated or manipulated. The European Commission says these transparency obligations apply from 2 August 2026 (European Commission).

Technical standards help here too. The C2PA standard supports “Content Credentials”, which attach a verifiable history to a piece of media so viewers and platforms can see how it was made.

A responsible licensed video should carry a visible label (for example, “AI-generated, licensed likeness”), content credentials where possible, and a way to check that a licence exists.

The law is still moving

Rules about digital replicas are changing quickly, and they differ between countries and, in the United States, between states. At the federal level, a bill called the NO FAKES Act was introduced in Congress in April 2025 (S. 1367); as far as we could find when writing, it has not become law. The US Copyright Office has also recommended that Congress create a new federal protection against unauthorised digital replicas (US Copyright Office, July 2024).

For anyone licensing or using a likeness, the practical takeaway is simple: get specific written consent, keep a record of it, disclose AI use, and take advice for each country where the content will run.

Where Likeness fits

Likeness is a marketplace we are building around this idea: permission once, paid every time. Creators would set their rules once, businesses would request uses inside those rules, and every licensed use would be recorded and paid. We are still in development, and nothing on this page is an offer of a live service. If you would like to hear when we open, email [email protected] and tell us whether you’re a creator or a business.

This article is general information, not legal advice. Laws change and depend on where you are; speak to a qualified lawyer about your situation.

Sources

Next post