How to get consent for a digital replica or AI voice
Last updated 25 September 2026
If you're going to make a synthetic version of a real person's face or voice, my standard is written consent that names four things. What you're making, what it'll be used for, for how long, and what happens when they want it stopped. Don't assume a standard appearance release covers it. Those were written for a camera pointing at someone, not for a model trained on them, and broad future-media wording is a thin thing to rest a voice clone on.
The phrase to use is digital replica. It's the term the unions, the law firms and the UK government all use, and it forces a more honest conversation than "we're just doing a bit of AI on it". You'll also hear AI likeness, voice clone, digital double and, from people outside the industry, deepfake. They're all pointing at the same problem, which is someone's likeness doing something they never did.
Picture a situation. You're twenty minutes from the first interview of the day. The contributor is a warehouse supervisor who's never been filmed before, the client has just mentioned they'd like to generate other language versions from the audio later, and somebody hands you a release that was last updated in 2019. You can get a signature on a form that doesn't cover what you're about to do, or you can have an awkward conversation in a corridor with a crew waiting.
This page covers the paperwork and the conversation. The legal theory is covered well by the law firms, and I link to them where they're the better source.
I've made films for brands and charities for fifteen years, most of it filmed the traditional way. The part of this I keep coming back to isn't what the law says. It's that somebody has to hand a piece of paper to a real person and explain it, usually under time pressure, and that person deserves to understand what they're agreeing to.
Explore this guide
If there's one section to start with, begin with What goes on a digital replica release form. It's the checklist the rest of the page is built around.
- What counts as a digital replica
- Why a standard release shouldn't be assumed to cover it
- What goes on a digital replica release form
- Check the vendor's terms before you promise anything
- Wording you can start from
- How to raise it without killing the room
- When someone says no
- Withdrawal, and what it can honestly undo
- Scans, digital doubles and crowd work
- When the person has died
- Where the UK stands on likeness and digital replicas
- Keeping the evidence trail
- A short glossary
- Questions people ask
- Where to go next
What counts as a digital replica
A digital replica is a synthetic version of an identifiable person. A cloned voice reading new lines. A face generated or swapped so it appears to be them. A digital double built from a body scan, performing a movement they never performed. A lip-sync pass that puts different words in their mouth.
It isn't every AI tool that touches a timeline. Denoising an interview, upscaling an archive clip, generating a background plate with nobody in it, painting out a boom. None of that creates a version of a person. The wider question of where the line sits, and when any of it needs a label, is covered in my working standard for using AI ethically in video. This page assumes a real person is being replicated and you now need it in writing.
As a practical production test, if the output could be mistaken for a recording of that person doing something they didn't do, treat it as a replica.
Language versions are where this gets blurred most often. A conventional dub, with a different actor voicing the translation, isn't a replica of your contributor. A cloned version of their own voice speaking French, with their lips regenerated to match, is. Agreeing to "translate the film" isn't agreeing to the second one, so ask about it by name.
Why a standard release shouldn't be assumed to cover it
Most appearance releases grant broad rights in broad language. Worldwide, in all media now known or hereafter devised, in perpetuity. That wording has held up for decades because the thing being licensed was a recording of a performance that actually happened.
A replica is a different kind of thing. It's the capacity to make performances that never happened. The Ecaveo working paper on responsible AI in film production puts the distinction neatly, noting that "consent to be filmed reaches the filming, and reproduction is a separate permission". Whether an older release stretches that far is a question for a lawyer on the specific wording, and my production standard is not to find out the hard way.
UK agencies have reached the same view. Sandra Reynolds, a long-established UK commercial agency, has added a clause to its model terms prohibiting the unauthorised use, replication or exploitation of model images in AI applications without explicit written consent, and requiring any AI project to get prior written consent from both the agency and the model, setting out purpose, duration and scope. That's one agency's contractual position rather than a rule of UK law, but it tells you a standard booking with them doesn't carry AI rights.
Performers are pushing the same way, with 2,348 models signing the British Fashion Model Agents Association's My Face Is My Own petition in September 2025 to demand express written consent for any AI use of their likeness.
Where legislators have acted, they show the level of specificity now being demanded. In California, a contract clause letting a replica stand in for work the performer would otherwise have done in person can be unenforceable for new performances if it doesn't give a reasonably specific description of the intended uses, unless those uses stay consistent with the contract and the character of what was recorded. It also has to be the case that the performer wasn't represented by a lawyer who negotiated the replica terms, with the commercial terms clearly set out in writing they signed, or by a union whose agreement expressly covers replicas. In New York, fashion work has been covered since 19 June 2025 by rules requiring clear written approval from the model before a replica is created or used, covering scope, purpose, pay and duration, and an agency's power of attorney can no longer cover a model's replica. None of that binds a UK shoot. It's still a useful picture of where the drafting standard is heading.
What goes on a digital replica release form
Here's what a replica consent needs to name, and what to write in each box. It's my working checklist rather than a legal template, and it's meant to be taken to a lawyer, not instead of one.
| Clause | What to write | Why it matters |
|---|---|---|
| Who is consenting | The person's own name and signature. Not their agent, not their employer, not a line manager signing for staff. For under-18s, a parent or guardian too, plus the young person's own agreement wherever they're old enough to give it. | Anyone else's signature is the weakest link in the document. |
| What is being made | Plain words. A cloned voice. A face replacement. A digital double from a body scan. A lip-sync pass for other languages. | If they can't picture the output, they don't really know what they've signed. |
| Source material | The specific recording, scan or archive, with dates. | It stops a replica being rebuilt later from different material. |
| Rights granted | Separately, whether you may create the replica, use it, generate new performances with it, and distribute what it makes. | Most disputes live in the gap between creating and using. |
| What it will say and do | The script, the subject matter, or a defined range. Product explainers in the register used on the day, for example, and nothing outside it. | It's where most drift happens, inside the contract but outside what they imagined. |
| Where it runs | Named channels, territories and formats, with paid media called out separately from organic. | A paid campaign abroad isn't the internal video they agreed to. |
| How long | An actual end date. Twelve months, twenty-four months, a named campaign window. | The asset outlives the shoot. If a client insists on perpetuity, price it as a buyout. |
| Reuse | Whether it can appear in another campaign, another production, a localised version or a library. Default is no without fresh consent. | Reuse turns a one-project consent into a library licence. |
| Authorised users | Who may exercise the permission. Producer, client, agency, post house, and the named AI vendor. | Every extra party is another place the replica can travel. |
| Money | The fee for creating the replica, and separately what's paid for each use beyond the agreed scope. | It stops a one-day fee becoming three years of free performance. |
| Training | Default no. Beyond building the replica itself, the material and the model may only train or fine-tune other systems, including the vendor's own, if explicitly ticked yes. | The clause people care about most, and the one most often left out. |
| Ownership, custody and deletion | Who owns the model, who holds it and where, who can order its deletion, and the date it's deleted from live systems, with written confirmation. | Consent to make it isn't consent for it to live on someone else's server. |
| Output approval | Whether the person gets to see or hear generated material before it's published. Script approval, final approval, consultation, or none. | For a cloned voice saying new words, this often gets the yes. |
| Prohibited uses | Political content, implied endorsement of a third party, sensitive categories, and anything the person names themselves. | Ask what they'd hate. Writing it down makes the document theirs. |
| Withdrawal | How they ask to stop, who they contact, the notice period, and what can and can't be pulled back. | Be honest about what can't be pulled back. More on this below. |
| Death and estate | Whether consent survives the person, and who decides if it does. | Awkward to raise now, far worse to resolve later. |
| What they were shown | The preview, sample, script or reference they saw, with the date, and the approved version the consent attaches to. | If there's ever a dispute about what they agreed to, this is the evidence. |
The last row is the habit that's saved me the most trouble. Consent tied to a project is vague. Consent tied to what the person actually saw, and to the approved master, is checkable. If the approved cut is v03, the record says v03, and a client asking for a v04 with a changed line has asked for something the consent may not cover. Get it confirmed in writing rather than assuming a small edit is fine.
Old material is the commoner trap in corporate work. A 2019 interview, a conference keynote, a recorded webinar. Permission to film someone then isn't permission to build a replica from that footage now. If the source is archive, the consent still has to be fresh.
A deletion date also means nothing without a definition. Deleted should mean the source files, the derived model, any fine-tuned weights and the vendor's own copies, removed from live systems by the agreed date and confirmed in writing by whoever holds them. Backups usually can't be wiped to order, so expect those to fall away on the vendor's normal cycle, and ask how long that cycle is.
Check the vendor's terms before you promise anything
This is the gap a producer is most likely to fall through. The contributor signs a form saying no training and deletion by a named date. The session then goes up to a voice or avatar platform whose default terms allow it to use customer content to improve its models. The vendor isn't bound by your form. Its terms with you decide what happens to the file, which means you've promised the contributor something you may not be able to deliver. You can't promise a deletion or a no-training position your vendor won't honour.
Before you put a vendor's name on a consent form, find out what its own terms let it do with the source recordings, the scans, the resulting model and the outputs. Whether it keeps any of them, and for how long. Whether training on customer material is on by default and whether you can switch it off at account level. Where the data sits and who its subprocessors are. Whether it'll delete on instruction and confirm that it has. What happens to the model if the account closes.
Then turn training off in the product itself, not only on paper, and keep a screenshot of the setting with the consent record.
Watch the handover too. On brand work the client will often want the model in their own asset library at the end of the job. That's a new party holding the replica and very likely a new use, so it needs to be in the consent from the start or agreed afresh.
Wording you can start from
Not a template, and not drafted by a lawyer. A starting point to take to one. None of it binds your AI vendor, which isn't a party to the form. It binds the producer, who then has to instruct the vendor.
A scope clause might read like this. This consent covers a synthetic version of my voice, created from the recording session on [date], for use in [named project]. It may be used for [described content] on [named channels] in [territories] until [end date]. Any use outside this scope needs fresh written consent from me.
For training, something this direct. Beyond creating the replica described above, the recordings, the resulting model and any derived material may not be used to train, fine-tune or improve any other artificial intelligence system, including a general model. [Producer] will instruct any vendor it uses accordingly.
For custody and deletion, promise only what you control. The model and source files will be held by [named vendor] and deleted by [date]. [Producer] will instruct [named vendor] to delete them and pass the vendor's confirmation on to me.
For money, separate the creation from the use. I will be paid [fee] for the creation of the replica and its use within the scope above. Any further use requires a new agreement and a new fee.
For review, say what they'll see and how long they have. The standard, whether consultation or approval, is the lawyer's call. I will be shown the generated material before publication and given [number] working days to raise objections, which [producer] will consider in good faith.
For withdrawal, frame it as something the parties agree, and be honest about the limits. The parties agree that I may ask for use of the replica to stop by writing to [named person]. From the date that request is received, no new material will be generated, and [producer] will remove the material from channels it controls within [period]. [Producer] cannot guarantee the removal of copies it doesn't control, such as material already shared, downloaded or re-uploaded by others.
And for a freelancer, the clause that matters most. Declining a future use will not affect my fee or engagement for the work already agreed. It takes away the fear that saying no will cost them.
How to raise it without killing the room
The conversation goes badly when it arrives late, and it arrives late by default, because the AI plan is usually made by somebody who isn't in the room on the day.
Raise it at casting or booking, not on set. If you know at the brief stage that language versions or a voice clone are wanted, the consent conversation belongs in the same email as the fee. A contributor who first hears about it in a corridor will reasonably assume they're being managed.
Show them something. Thirty seconds of what a cloned voice sounds like, or a comparable shot from another project, moves people from anxious to decided faster than any explanation. Most of the fear is of something they can't picture.
Say the scary part first. Tell them plainly you're proposing to make a version of them that can say things they didn't say. If that sentence makes the client wince, the client has learned something useful about the thing they asked for.
Send the form before the shoot day. Ten minutes in a corridor isn't a fair window to read a document about your own face.
Staff are the harder case, and corporate work is where these requests usually start. Asked in front of a manager, people aren't really free to refuse, and the ICO is wary of relying on employee consent under UK GDPR for exactly that reason. A signed form from a member of staff isn't the same instrument as a freelancer's. Ask privately, and before a replica is built from staff footage, make sure the client has properly looked at the data protection side, including whether consent is the right basis at all and how someone can opt out without going through HR. As the producer I can't promise anyone their job is unaffected, so don't let the form pretend to.
Take extra care with young people. Brand and charity films use under-18s all the time. My standard is a parent or guardian's signature plus the young person's own agreement wherever they're old enough to give it, and I won't create an open-ended digital double of a child for anyone.
Write down what they ask for. If somebody says they don't want it used in recruitment content, that goes in the prohibited uses box before they sign, not into your memory.
When someone says no
Handling a refusal
Respect the answer, then work the problem
Work down in order. Each step is only worth taking if the one above it hasn't settled things.
-
01
Accept it in the room
Take it at face value and don't negotiate in the moment. A refusal that gets argued with becomes a complaint later, even if the person eventually agrees. Thank them, and move on in front of them.
-
02
Find out which part they object to
It may be how broad the proposal is rather than the technology itself. Ask which part bothers them, not whether they've changed their mind.
-
03
Narrow the ask
A voice model held indefinitely by a vendor is a very different request from one generated for a single campaign and deleted in ninety days.
-
04
Offer a route that doesn't need a replica
Re-record the pickup lines, book a short session, or cast a different performer for the synthetic element. Sometimes the sequence can use voiceover instead of a piece to camera. Very often the AI plan was a convenience rather than a necessity, and it's worth telling the client so.
-
05
Put the refusal on record with the client
If the client wants to press on, that decision belongs in writing with them, with the facts in front of them, not quietly absorbed by the producer.
-
06
Know where you stop
If a client wants to go ahead against a refusal, that's the moment to decline the work rather than find a workaround.
That last step matters because the UK has no standalone personality or image right of the kind some US states have. Other protections can still apply, data protection in particular, since someone's face or voice processed to build a replica is personal data. But contract carries more of the weight here than it would elsewhere, which is exactly why a refusal has to be respected.
Withdrawal, and what it can honestly undo
A well-drafted agreement will usually include a way for the person to ask for use to stop. UK law doesn't hand them a general right to cancel any contract at will, so the mechanism has to be written in. What almost no one is honest about is what withdrawal can achieve, and that's where trust collapses.
Depending on your agreement and your vendor's terms, you can stop generating new material, take the content down from channels you control, instruct the vendor to delete the model and the source files, and pass on its confirmation. You can't recover a file somebody downloaded, unpublish a third-party re-upload, or reach into a partner's asset library in another market.
Say that at signing, not at the point of withdrawal. People who understood the limits when they agreed will accept them. People who discover them during a crisis won't.
It helps to keep the model with one named vendor rather than spread across three, so deletion is a single instruction. And don't publish clean isolated dialogue or voice tracks without a real reason, because an isolated track is the most useful thing you can hand to someone who wants to clone a voice without asking.
Scans, digital doubles and crowd work
Body scanning has its own problem. It's usually done in bulk, quickly, and to people at the bottom of the call sheet. Background artists and stunt performers get scanned in a queue, and nobody stops the queue to explain what the scan is for.
A scan is source material rather than the replica itself, but if it's being captured to create or enable a digital double, treat it as part of the replica workflow and put it in the consent. Same rules. Named purpose, named duration, named deletion date, and a clear position on whether it can be reused on a different production. Reuse is where scan grievances come from, because a scan library is valuable precisely because it can be reused.
On a scan day, a few habits keep it straight.
Consent signed per person, never per group or per agency booking
A one-page plain-English summary handed over before the scan, not after
A log matching every scan file to a signed consent reference
The scan's purpose and deletion date stated to the person out loud
Nobody scanned who hasn't signed, however far behind the queue is running
For crowd work, the honest test is whether the individual stays identifiable in the output. A digitally multiplied crowd where nobody's recognisable is a different proposition from one performer's scan reused as a named character. Even where nobody can be identified in the output, scanning them to get there is still processing their personal data, and the trap is assuming no one will be recognised when a distinctive feature gives them away to people who know them.
When the person has died
If you're recreating someone who has died, the first job is to establish who actually has the authority to grant the rights you need. Depending on the jurisdiction and the arrangements, that could be an estate, an executor, a family trust or a rights company, and they don't always agree with each other.
Settle two things early. Who can say yes, in writing, with evidence that they hold the right. And what the person had said, if anything, while they were alive. Where an estate agrees to something the person was publicly against, you may be legally clear and still doing something your audience won't forgive.
Build in more time than seems necessary, and be ready for the answer to be no.
Where the UK stands on likeness and digital replicas
Checked on 25 September 2026. This area is moving, so verify anything load-bearing before you rely on it.
| Position | Status |
|---|---|
| A standalone right over your own likeness | Doesn't exist in UK law. People rely on a patchwork of passing off, data protection, defamation and performers' rights. |
| A new digital replica or personality right | Under consideration. The government's Report on Copyright and Artificial Intelligence, published 18 March 2026, acknowledged gaps in how existing law handles digital replicas and committed to exploring further protection. |
| The promised consultation | The Secretary of State's written statement of 18 March 2026 promised a consultation on digital replica harms for the summer. At the date above, I couldn't find that it had opened. |
| How the patchwork holds up | Largely untested in the UK courts on digital replicas, which is why producers lean on contract. |
| Personal data in a replica | A face or voice used to build a replica is personal data, and biometric data used to identify someone can be special category data. The ICO guidance on AI and data protection is the baseline. |
| Performers' collective agreements | Equity and Pact have been negotiating AI terms for UK film and TV, including scanning and training on performances. In an indicative ballot closing in December 2025, 99.6 per cent of those voting backed refusing digital scanning on set. Being indicative, it didn't instruct members to refuse scans. As at 11 September 2026 no AI agreement had been concluded, according to the Ecaveo paper. Separately, a new TAC and Equity agreement for S4C productions, adopted in May 2026, includes AI protections, so the Pact position isn't the whole UK picture. |
Until a dedicated right exists, the document you wrote carries more weight than it would in a jurisdiction that has one.
Consent registries are worth knowing about but they aren't a substitute. The most visible is the Human Consent Registry from RSL Media, the non-profit co-founded by Cate Blanchett, which lets people declare whether AI systems may use their name, image, voice, likeness and movement, on an allowed, allowed with terms or prohibited basis. It's a useful signal and worth checking. It isn't a release, compliance with it is voluntary, and an entry saying prohibited doesn't tell you whether the person would refuse your specific project. Ask them.
Keeping the evidence trail
Consent isn't just the signed form. It's the evidence of what the person actually agreed to, and it gets lost because it lives somewhere sensible to the person who created it and nowhere sensible to anyone else.
Keep the signed consent in the same place as the approved master, named with the same version. Keep the preview or sample they were shown, because "they knew what it would sound like" is much stronger when you can produce the file they heard. Keep the vendor's deletion confirmation, the screenshot of the training setting, and the name of the person who handles withdrawal requests, so it all survives the producer leaving.
If there's a handover to a client or agency, the consent pack goes with it, along with a short note on what the consent doesn't cover. Handing over assets without their limits attached is how scope drift starts. It's also worth telling your production insurer if a job involves a replica, since an undeclared one can become a coverage problem.
If a replica ever turns up somewhere it shouldn't, that trail is what lets you answer quickly and openly, with what they signed and what they were shown. Arguing about rights doesn't calm these situations. Facts do.
What this page is and isn't
This is practitioner guidance on paperwork and process, written by a filmmaker rather than a lawyer. Where it describes the law, I've tried to say so and date it. Where it describes what I'd do, that's my production standard, not a legal requirement. It isn't legal advice, and nothing here replaces advice on a specific project, particularly a commercial campaign, anything crossing jurisdictions, or anything involving a person who has died.
What I can tell you is what the document needs to say and how the conversation goes when you have to have it.
A short glossary
| Term | What it means here |
|---|---|
| Digital replica | A synthetic version of an identifiable person's voice or likeness. The UK government's working definition covers images, video and audio made with digital technology to realistically replicate someone's voice or appearance. |
| Likeness | The recognisable features of a person, including face, body, voice and distinctive mannerisms. |
| Source material | The recordings, scans or footage a replica is built from. |
| Training and fine-tuning | Using material to build or improve an AI model, whether a general one or one specific to the person. |
Questions people ask
Does a standard appearance release cover AI use?
Don't assume it does. Standard releases license a recording of something that happened, and a replica makes performances that never happened. Whether a specific release stretches that far depends on its wording, so get a separate, specific consent for the replica.
Does consent to create a digital replica mean consent to use it?
No, and this is the distinction most forms miss. Creating it, holding it, using it, reusing it, distributing what it makes and training on it are separate permissions. A good consent deals with each one.
Do I need a separate consent for a voice clone?
Yes, and keep it separate from the appearance release rather than buried inside it. It should name the source recording, the permitted content, the duration, the position on training, who holds the model and when it's deleted.
Can someone withdraw consent after the video is published?
Only if the agreement gives them a way to, which it should. Withdrawal can stop new material, take content down from channels you control and get the model deleted. It can't recover copies already downloaded or re-uploaded elsewhere.
Does UK law give you a right over your own likeness?
Not a standalone one. Protection comes from passing off, data protection, defamation and performers' rights, depending on the facts. The government promised in March 2026 to consult on digital replica harms, with a possible new right among the options.
