New York’s AI-generated performer disclosure law

What the law requires

If an advertisement distributed in New York contains a synthetic performer, the ad must clearly tell viewers that the performer is not a real human. The disclosure has to be conspicuous and placed within the advertisement itself.

What counts as a “synthetic performer”

The law defines a synthetic performer as a digitally created, reproduced, or modified asset generated through AI or a software algorithm that creates the impression of a human performance, but is not recognizable as an identifiable real person. That can include:

• AI-generated models, actors, influencers, or avatars
• AI-generated or substantially modified faces, hands, voices, or other human features
• Lifelike digital people shown using, presenting, or promoting a product or service

Illustrated characters, 2D animation, and visibly stylized 3D characters may carry less risk than photorealistic AI people. The law does not automatically exempt all illustrated or cartoon-style human characters, so each should be reviewed on its own rather than assumed to be compliant.

How AI Notify helps you comply

AI Notify is built around the exact standard this law sets: honest, visible disclosure on the creative itself.

Ways to stay compliant

• Add a clear disclosure such as “AI-Generated Model” directly to creatives that contain synthetic performers.
• Use licensed stock photography featuring real human models.
• Avoid human models in advertising creatives.
• Exclude or separately segment New York audiences from campaigns that use undisclosed AI-generated human models.
• Use non-human graphics, product-focused designs, or other formats that do not present a synthetic human performance.

What the law exempts

• Audio-only advertisements.
• AI used solely to translate the language of a real human performer.
• Certain promotional materials for movies, television, streaming content, documentaries, video games, and similar expressive works, when the synthetic performer’s use is consistent with the underlying work.

Penalties

Publishers and advertising platforms generally receive protection for ads created by others. The primary responsibility falls on the person or company that knowingly produces or creates the advertisement.

What to do before June 9, 2026

Review all active and scheduled advertisements that contain AI-generated or substantially AI-modified human figures. Any affected creative should be replaced, properly disclosed, or excluded from New York distribution before the effective date.

Read the official legislation (NY Senate Bill S8420 / A) →

This page is provided for general information and operational planning. It is not legal advice. Confirm the final disclosure language and placement standards with qualified legal counsel before relying on them.