New York has put a disclosure requirement on AI-generated people in advertising. For teams using synthetic media, the practical question is no longer whether the content looks real, but whether it is clearly labeled.
New York Enacts Law Requiring Disclosure of AI-Generated 'Synthetic Performers' in Advertisements
New York has implemented a law requiring advertisements that feature AI-generated people to clearly label them as “synthetic performers,” according to The Washington Post. The measure is designed to improve transparency in media by making it easier for audiences to tell when a human likeness in an ad was generated rather than filmed or photographed. It does not prohibit the use of AI-generated people in commercial creative work; instead, it sets a disclosure obligation at the point of publication. That makes it a practical compliance rule for marketers, agencies, and production vendors already using generated faces, bodies, or spokesperson-style avatars.
The law arrives as AI-generated content is becoming a routine part of advertising workflows, from concept art and virtual models to fully synthetic video spots. New York’s approach is notable because it targets the output layer rather than the underlying model or tool, signaling that regulators are willing to allow synthetic media if consumers are told what they are seeing. For brands operating nationally, that raises a familiar problem: one state-level rule can effectively become a broader internal standard if teams want a single review process across campaigns. In practice, disclosure will likely require coordination among legal, creative, media, and platform operations teams before assets go live.
- Advertising teams will need a formal review step for synthetic assets so labels are applied consistently before campaigns are released.
- This pushes governance beyond model procurement and risk assessment into the public-facing output itself, where compliance failures are easier for regulators and consumers to spot.
- Brand, legal, and creative teams will need a shared operational definition of what counts as an AI-generated person, especially in mixed workflows that combine edited human footage with generated elements.
- Any workflow using generated faces or bodies may need documentation showing how the asset was created and why a disclosure decision was made, which has implications for audit trails and vendor contracts.
