The New York Fashion Workers Act (S9832) regulates model management companies and includes some of the strongest AI provisions in any labor law. It has been in effect since June 19, 2025, after being signed December 21, 2024 as Chapter 676.
Digital Replica Rules in the New York Fashion Workers Act
The law defines a model’s digital replica as a computer-generated or AI-enhanced representation of their likeness. Creating or manipulating one without clear, conspicuous written consent obtained separately from the representation agreement is prohibited. Clients must also get separate prior written consent detailing the scope, purpose, pay, and duration of any AI use of a model’s likeness.
What Brands and Agencies Should Do
Brands and agencies shooting campaigns in New York need explicit AI consent paperwork for any digital replica work. Because the consent must be separate and specific, a general clause buried in a standard contract will not satisfy the statute. Building dedicated AI consent forms into campaign workflows is the practical fix.
Source: New York State Senate: S9832
Report a violation: If you believe a business is violating this law, you can file a complaint with the New York Attorney General Consumer Frauds and Protection Bureau.
