Using a real person's face or voice in AI content: a consent checklist and release wording

An AI likeness is a copy of a real person's face, body or voice that a tool can then make say or do new things. The tool might be a lip sync (matching mouth movement to audio) feature, a voice clone (a synthetic copy of a voice built from a recording), or an AI twin built from a few photos. The person never stood in front of a camera for those new scenes, so the old paperwork often does not fit.

This page is about the paperwork. I give you a checklist, a clause-by-clause release to adapt, and a way to sign and keep it. It is general information, not legal advice. Right of publicity (a person's control over commercial use of their name, image and voice) and privacy rules differ by country and by US state, so have a lawyer review the wording you end up using.

This page may contain affiliate links from which Blur Studio earns commissions.

Why a normal release is no longer enough

A standard model release says something like "you may use photos and video taken on this day." That covers the footage that exists. It does not clearly cover a tool that learns a face and then produces footage that was never filmed. If the person is later shown saying a sentence they never said, "I only agreed to a photo shoot" is a strong complaint, and it is a fair one.

The tools also put the burden on you. Higgsfield, an AI image and video platform, says in its Terms of Use (sections 4.2(b) and 5.3, last updated 23 October 2026) that the user warrants, meaning promises, that they hold all rights, releases and consents for any identifiable person's likeness or voice in what they upload. Section 3.1 adds that the user is solely responsible for the content they put in. Other platforms have similar wording. So the signed form is your evidence. The tool will not produce it for you. For the wider rights picture, see can you use AI video in paid ads for clients.

YouTube's help page requires disclosure when AI makes a real person appear to say or do something they did not, and the EU AI Act has a duty for people who publish deepfakes (realistic AI image, audio or video of real people). Labelling is a separate job from consent, covered in the platform label rules page. Consent comes first. A label does not fix a missing signature.

Who must sign

Anyone whose face or voice can be recognised in the output. Go through this list for each project.

• The person themselves, in their own name. Not a manager, not a friend who "says it is fine."
• A parent or guardian for anyone under 18. Many platforms also have their own rules about minors, so the platform may refuse the upload even with a signature. Treat children's likeness as a lawyer question.
• Employees. A signature given because the boss asked is weak consent, because the person may feel unable to say no. Use a separate document from the employment contract, make it clearly optional, and say that refusing has no effect on their job. Staff announcements raise more issues, covered in AI video for HR and internal announcements.
• Customers and clients. Get their consent in a document that names AI use. A line in a general terms page is not enough for a recreated face or voice. For plain customer consent paperwork, see the customer consent form template.
• Family members and friends. They sign too.
• Actors, voice artists and creators. Professional talent often has union or agency rules. Their paperwork may be stricter than anything here, and it wins over a template.
• Someone who has died. Do not proceed on a template. The rights may sit with the estate, and rules vary a lot. Ask a lawyer.

Your own face and your own voice need no one else's signature. Even so, write down the date you decided and the tool you used. The same record habit helps you later, and I come back to it below.

The 10 clauses of an AI likeness release

This is a starting structure, not finished legal text. Replace each bracket with your facts. Keep each clause short and in plain words, because a person who does not understand what they signed has not really consented.

1. Who and what. "I, [full name], agree that [business name] may create and use an AI-generated version of my [face / body / voice] (the 'AI likeness') as described below." Name the person and the company exactly.
2. Source material. "The AI likeness will be built from the following photos, video or audio that I provided: [list]." List the files. This stops the scope from creeping to other material later.
3. Tools allowed. "The AI likeness may be created and processed with [tool names, for example Higgsfield, ElevenLabs]. Any other tool needs my new written approval." Platforms may keep or train on uploads under their own terms, so say that plainly: "I understand that tool providers have their own terms, which may allow them to keep or learn from uploaded content."
4. Allowed uses. A closed list. For example: "organic social posts on [accounts], paid ads on [platforms], the company website, internal training videos." If it is not listed, it is not allowed.
5. Banned uses. At least: political or religious messages, adult or sexual content, anything that suggests I endorse a product I did not choose, medical or financial claims, anything that shows me saying something that is false or harmful. Add anything the person asks to exclude.
6. New words and scenes. Decide this one on purpose. Option A: "I approve each new script and each finished video before it goes live." Option B: "I approve the scripts and the style rules, and the company may produce videos within them without further approval." Option A costs time but protects the relationship. Never leave this clause out, because it is the main thing that a normal release does not cover.
7. Where and for how long. Territory (countries or regions) and a term (for example 12 months, renewable in writing). Open-ended "forever, worldwide" releases are the ones that cause fights.
8. Payment or other value. State what the person receives, even if it is "no payment." A clear line avoids a later claim that the deal was unfair or never agreed.
9. Withdrawal. "I may withdraw consent by writing to [email]. The company will stop new use within [10] working days and will remove the AI likeness from active campaigns and from its own channels within [30] days. Content already posted by third parties, and material the company must keep for legal reasons, may remain." State what you cannot pull back. Content that has been shared or reposted is hard to recall.
10. Signatures, date and (if needed) guardian. Printed name, signature, date, and a second signature block for a parent or guardian when the person is under 18. Add a line: "I read this in full, had time to ask questions, and sign freely."

Two optional clauses help. A data clause: "The company will keep the source files and the AI likeness in [location], limit access to [roles], and delete them within [30] days after the term ends or consent is withdrawn." And an exit clause for employees: "If I leave the company, my AI likeness will no longer be used for new content after my last day." Decide that before the person leaves.

What belongs outside the form

Do not put these in the release, because a signature cannot make them acceptable.

• Fake endorsements. The US Federal Trade Commission (FTC) says in its consumer reviews and testimonials Q&A that using a celebrity's likeness without permission to suggest an endorsement breaks its rule. It does not ban AI avatars as such, but it targets testimonials that are false. If an AI person says "I used this and loved it" and nobody did, a release does not save you. See the page on fake testimonials and AI reviews.
• Sensitive details in prompts. Higgsfield's terms (section 5.4) say not to put sensitive personal data in prompts.
• Private people on platforms that ban it. TikTok's support page says it does not allow AI content showing the likeness of adult private figures used without their permission, or of anyone under 18. A signed release helps with the permission part for adults, but the under-18 rule stands whatever you sign.
• Tricking an audience. A release does not give you the right to hide AI use where a platform or a law requires a label.

A shoot release versus a digital-replica release

This is the point most guides miss. A real-shoot release covers footage that was filmed. A digital-replica release covers footage that was never filmed. Put the two next to each other and the gaps are clear.

Question	Real-shoot release	AI likeness release
What exists after signing	Footage from one session	A reusable copy that can make new footage
New words or scenes	Not applicable	Must be addressed (clause 6)
Third-party tools	Rarely mentioned	Named (clause 3)
Withdrawal	Often silent or "all rights"	Clear steps and limits (clause 9)
Exit of an employee	Rarely covered	Decided in advance

If a person signed an old shoot release (here is a standard photo and media release form), do not stretch it. Ask for the new one.

Employees, customers and voices

Voice deserves its own mention. A voice clone can be used on phone calls and in ads and is easy to misuse. Name "voice" separately from "face" in the release. Some tools also ask for a live verification, such as reading a short phrase on camera, before they build a voice. If a tool offers that, use it, and do not claim any tool has such a step until you have read its current rules. I compare the main options in the voice cloning tools page.

Cloning your own voice for a voiceover is a special case in YouTube's disclosure rules, which exempt it. That exemption is about labelling. It says nothing about whether you may clone someone else's voice. For talking-presenter videos where staff do not want to be on camera, the talking presenter page covers the steps with consent included, and the staff headshots page covers a smaller version of the same problem. If you use Higgsfield's lip sync, the lipsync guide explains the tool, and the lip sync roundup puts consent first for each option.

What the form cannot do

A signed release helps a lot. It cannot override the law. A few examples, all hedged because they change.

• Some places have laws that protect voice and likeness against AI copies. Tennessee's ELVIS Act, which covers voice, is one often cited, and law-firm write-ups from 2024 describe a patchwork of state rules and no single federal right. The 2026 position is unconfirmed here, so check current law.
• News coverage from 2024 said the FTC's impersonation rule applies to government and business impersonation, and that an extension to individuals, which would reach voice clones, had been proposed. Whether it was finalised is unconfirmed here.
• The EU AI Act's Article 50 sets disclosure duties for deepfakes. The official dates and amendments are summarised on the pages linked in the sources. Information, not legal advice.

In short, the form is necessary but not sufficient. Ask a lawyer to adapt it to your country, and for anything involving minors, a deceased person, a celebrity or a health or political topic, get legal advice before you proceed.

Signing it online and storing it

Paper works, but it gets lost. A signed PDF with a date and a record of who signed is easier to find when someone asks a question a year later. An e-signature service sends the document to the person, collects the signature, and keeps a record. One option is QuickSigner, an e-signature service, for this kind of one-page form. Other services work too, and the e-signature comparison for agencies lists them. Check the current features and price on any vendor's own page before you choose.

Whatever you use, set it up like this.

1. Send the release before any upload, at least a day ahead, so the person can read it without pressure.
2. Ask the person to confirm by signature, not by "reply YES" in a chat.
3. Check that the finished document shows the date, the signer's name and which version they signed. The audit trail page explains what a good record includes.
4. Store the signed file together with the source photos or voice sample and a generation log: tool, date, prompt and the name of the output file. If the person ever withdraws consent, you know exactly what to remove.
5. Diary a renewal date at the end of the term, and a six-month check on live content.

Whether an electronic signature counts as valid depends on where you and the signer are. The plain guide to e-signature validity covers the basics. The page on whether AI tools train on your uploads lists questions to ask. Higgsfield's terms (section 4.4) say it may use content for training, with a different arrangement for customers under an Enterprise Agreement, so you cannot promise a signer that a copy will never be learned from unless the tool's contract says so.

A takedown and withdrawal routine

Write the routine before the first request arrives.

• One email address for withdrawal requests, checked weekly.
• Day 1: acknowledge in writing and pause new use of the likeness.
• Within 10 working days: remove it from paid campaigns and scheduled posts.
• Within 30 days: delete the AI likeness and source files from tools you control, and ask the tool provider to delete them where its settings allow. Keep the signed release and the log, since they are your record.
• Tell the person what you could not remove, for example copies others reposted.

Tool terms also matter. Some platforms may embed provenance marks (hidden or visible signals that show where an image or video came from). Higgsfield's terms (sections 5.5 and 6.4) say it may do this, with no warranty that the marks will last, and that users must not remove them. That affects your takedown story, because labelled content can travel further than you expect.

Review checklist before you publish

• Every recognisable person has signed, or is covered by a guardian's signature.
• The signature is dated before the first upload.
• The tool used is named in the release, and its terms permit this use.
• The uses planned are on the allowed list and not on the banned list.
• New scripts follow the approval rule the person chose in clause 6.
• No fake testimonial, claim or endorsement is in the script.
• A label is added wherever a platform or a law requires one.
• The signed form, source files and generation log sit in one folder.
• A renewal date and a withdrawal address are on record.

When a lawyer beats this template

Use a lawyer, or the talent's own agency paperwork, for professional actors, minors, public figures, political, medical or financial content, and campaigns in several countries. This template is a first draft for a lawyer to review, not a replacement for one.

How I'd approach this

I would make consent a gate, not a step. No upload to any AI tool until the signed release is on file, the same way you would not publish a client photo without permission. Start with one short form sent for signature through an e-signature service such as QuickSigner, use the 10 clauses above, and cut anything that does not fit your case. Offer a "no thanks" path without any pressure, especially for staff. A one-page staff policy for AI creative tools keeps the rule the same for everyone.

Then keep the paperwork where you can find it: signed form, source files, generation log and a renewal date, in one place. If you run this for many clients or staff, Blur Studio can build the repeatable workflow around it, with a request form, a signature step and an approval portal, so nothing gets generated without the record. You can read more on the Blur Studio business page. Start with the form and the folder, though. They cost an afternoon, and they are what you will wish you had if anyone ever asks.