Can I reuse an AI model across campaigns?

If the model is fully synthetic, yes, with the labels each market requires. If it was built from a real person’s photos or is a digital twin, only within the uses, countries and term the person licensed.

What if our AI model looks like a celebrity?

Change the face before anything is published. Lookalikes have cost advertisers before: a New York court found that Dior’s ad with a Jacqueline Onassis look-alike infringed her rights. Have two people who did not make the image check it.

Does the GDPR apply to a synthetic person?

The GDPR protects identifiable natural persons. It applies to the real photos you use as references and to any twin of a real model. It is unlikely to apply to a face invented from scratch that matches no real person.

Do I need a new release for a real model whose photo I change with AI?

Check the release you have. If it covers photography but not AI changes to face or body, get the model’s written consent for the new use. New York requires written consent before a person’s likeness is used in advertising at all.

Do AI-generated models need model releases?

Checked September 24, 20266 min read

Short answer

Not if the person exists only in the AI output, because there is nobody to sign one. You need written consent once a real person is involved: their photo as a reference, a digital twin of a model, or a face that ends up resembling someone. New York requires ads to disclose AI-generated people, EU guidelines treat realistic AI people in ads as deepfakes that need a label, and SAG-AFTRA’s 2025 commercials contracts set consent and pay rules for replicas.

Three kinds of AI model

Kind of model	Example	Release or consent?	Rules that still apply
Fully synthetic	A face generated from a text description, with no real person’s photo as input	No one to sign	New York ad disclosure, EU AI label, Amazon tag, FTC rules if shown as a customer, lookalike risk
Synthetic, built from a real person’s photos	A new face made from a staff member’s or stock model’s photo	Yes, from the person in the photos	Publicity rights, GDPR in the EU, the photo’s own license
Digital twin	A licensed AI version of a real model, used across campaigns	Yes, a written license	State contract rules, union rules, publicity rights
Real photo changed with AI	A shoot photo with the pose, body or face altered	Check that the existing release covers AI changes	Publicity rights, and FTC rules if the change misleads

Synthetic people: what still applies

New York. Since June 9, 2026, General Business Law § 396-b requires anyone who produces an ad to disclose conspicuously that it contains a synthetic performer, a digitally created human who is not recognizable as any real person, when they know it does. Penalties are $1,000, then $5,000 per violation.
EU. The Commission’s July 2026 guidelines count realistic AI-generated human avatars and personas as persons for deepfake purposes, and give a realistic synthetic influencer testing a sponsored product as an example that needs a label. See the EU AI Act guide.
Amazon. Since July 2026, listing and A+ images or videos showing a photorealistic AI-generated person need the keyword contains-synthetic-performer in their XMP metadata, in every Amazon store. Real people edited with AI do not need it. See AI images on Amazon.
US federal. The FTC says there is no blanket ban on AI avatars in marketing, but an ad that presents people as actual consumers must show actual consumers or clearly say they are not (16 CFR 255.2(c)).
Resemblance. A synthetic face can land close to a real person by chance. The Copyright Office’s 2024 digital replica report records concern about accidental lookalikes, and a New York court ruled against Dior over a look-alike in its ad in 1984. Check every face.
Industry guidance. The IAB’s August 2026 framework asks for a label on photorealistic AI people in main roles, and not on AI figures in the background.

Digital twins of real models

A digital twin is an AI version of a real person that can appear in new images they never posed for. H&M said in March 2025 that it would make twins of 30 models that year, and that the models would own their twins and could license them to other brands, including competitors. An H&M business developer told Business of Fashion that pay would work like usage rights on a shoot.

Two large states set hard rules for these contracts. In California (Labor Code § 927, for performances from January 1, 2025) and New York (General Obligations Law § 5-302), a clause that lets a replica do work the person would have done in person cannot be enforced if it lacks a reasonably specific description of the uses and the person had no lawyer or union negotiating for them. Include the description, and make sure the performer has a lawyer or union representative.

The federal NO FAKES Act of 2026, which the Senate Judiciary Committee sent to the full Senate on June 24, 2026, would cap licenses from living people at 10 years and require a signed, written license with a reasonably specific description of the uses. It was not law on September 24, 2026. See AI images of real people.

Union talent: the 2025 SAG-AFTRA commercials contracts

If you hire SAG-AFTRA performers for commercials, the union’s 2025 Commercials Contracts set the rules for replicas. Members approved the three-year deal with the Joint Policy Committee, which bargains for national advertisers and agencies, by 96.90% to 3.10%.

Consent is required before any digital replica is made, and informed consent before each use, with a reasonably specific description of how it will be used.
Using a replica to create a performance pays 1.5 times the session fee, plus holding and use fees.
Replicas must be kept secure and destroyed after the maximum period of use, unless the performer agrees otherwise.
Performers’ data cannot be used to train AI without the union’s consent.
The union says the contract removes the economic advantage of using synthetic performers.

Stock photos do not come with AI permission

A stock model signed a release for the stock agency’s license, and that license sets what you may do with the photo. Getty Images’ license, updated April 2026, bars using its content for machine learning or AI purposes beyond internal archiving and search and the editing the license already allows. On our reading, using a stock model’s face as an AI reference to make new images of them falls outside that license. The license also requires you to state that the person is a model when an image is used on a sensitive subject.

What to keep on file

AI talent record (one per person-like figure in a campaign)

Figure name or ID:
Kind: fully synthetic / built from a real person’s photos / digital twin / real photo altered
Reference images used, with source and license:
Real people involved, and signed consent or license (file name, date, expiry):
Uses allowed: channels, countries, formats, term:
Union performer? Contract terms and fees:
Resemblance check: who checked, when, result:
Labels applied: EU "AI" label, New York synthetic performer disclosure, Amazon tag, platform labels:
Where replica and reference files are stored, and when they must be deleted:

For casting synthetic people who reflect your customers, see casting AI models responsibly. For keeping one person consistent across a set, see how to keep the same model in every AI photo.

Questions people also ask

Can I reuse an AI model across campaigns?: If the model is fully synthetic, yes, with the labels each market requires. If it was built from a real person’s photos or is a digital twin, only within the uses, countries and term the person licensed.
What if our AI model looks like a celebrity?: Change the face before anything is published. Lookalikes have cost advertisers before: a New York court found that Dior’s ad with a Jacqueline Onassis look-alike infringed her rights. Have two people who did not make the image check it.
Does the GDPR apply to a synthetic person?: The GDPR protects identifiable natural persons. It applies to the real photos you use as references and to any twin of a real model. It is unlikely to apply to a face invented from scratch that matches no real person.
Do I need a new release for a real model whose photo I change with AI?: Check the release you have. If it covers photography but not AI changes to face or body, get the model’s written consent for the new use. New York requires written consent before a person’s likeness is used in advertising at all.

Where Overs fits

For worn or held products, Overs makes a character sheet of one model first; you approve it, and every later photo with a person uses that model. Approved sheets can be reused as a talent library, so record how each one was made and what went into it.

Free for 40 photos a month. The AI that makes the photos is billed separately, on your own key, with no markup from Overs.

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Sources

Checked on September 24, 2026. Prices, specs and rules change; follow the links for the current versions.