Jurisdiction · New York State
New York Fashion Workers Act.
The Act sets duties for covered model-management businesses and clients, including separate written consent for digital replicas. Registration requirements depend on the business and its New York activities.
Source checked · 6 September 2026 · applicability review pending
What it requires
- 01Separate, explicit written consent before any AI replica or AI likeness is created.
- 02Consent that specifies the replica's scope, purpose, pay rate, and duration.
- 03A copy of the contract delivered to the model in plain language.
- 04Registration for model-management companies doing business or providing services in New York.
- 05A private right of action for models, with remedies set by the Act.
Current implementation and gaps
- 01Mirai records a written likeness agreement for participating talent. Whether the agreement and any campaign-specific consent satisfy the Act for a particular engagement requires legal review; this page is not a compliance certification.
- 02Each per-image license a brand purchases is itself a scope-bounded sub-license under the master Likeness License. Duration, territory, exclusivity and format are recorded on every transaction.
- 03Every license a brand purchases against a model's AI likeness is recorded on the transaction and visible to the model in their dashboard in real time, format, duration, territory, and fee. Email delivery of license copies is in progress.
- 04Consent is protected by live, server-side mechanisms on every checkout: a model can withdraw at any point; licensing is refused outside the written scope she consented to; and print and out-of-home licences follow her own setting: on demand inside her rules, or her individual approval of the specific image. Digital licences complete under her standing written consent where she has granted one, which records its own version and timestamp.
- 05Models can revoke consent at any time by written notice to legal@mirai.inc. We stop new generations within 72 hours and retire the AI likeness from the roster; licenses already paid remain valid for their purchased term. One-click, self-serve revocation is in progress, today every request is handled by our team, manually and on the record.
- 06Consent versions and material platform events are recorded. A documented retention schedule and Mirai's registration obligations must be confirmed as part of the New York legal review.
What this means for brands
If you license imagery through Mirai, the model's consent is captured in writing, in plain language, with scope recorded and audit-logged, so the consent chain is documented before you license. Your legal team can pull our Likeness License and our Brand Acceptable-Use Policy into a vendor review. Brands remain responsible for their own campaign, advertising and disclosure obligations. Mirai's New York registration analysis and status are under counsel review.
For a copy of the license framework, email info@mirai.inc.