SB 1111: Digital Replicas and Employee Photos in Ads Need Consent From 2027

What changed

SB 1111 (Chapter 862, Statutes of 2026) makes clear that California's right-of-publicity law covers digital replicas, meaning realistic computer-generated versions of a person's voice or likeness. It also removes the rule that presumed an employer's use of an employee's photo or likeness, when incidental to an advertisement, was not a knowing use without consent. It takes effect January 1, 2027.

Who it applies to

Businesses that use people's voices or likenesses in advertising, including employers that feature employees, and businesses that create digital replicas.

Key dates

Effective date:

January 1, 2027

Law expanding digital-replica liability and removing employee-photo presumption takes effect; employers lose prior rebuttable-presumption protection for incidental employee photo use.

What employers may need to do

• Get an employee's consent before using their photo, voice or likeness in an advertisement, even when it is incidental, starting January 1, 2027.
• Treat an AI-generated digital replica of a person's voice or likeness the same as the real thing when getting consent.

Official source

Detected by RegWatch monitoring on October 1, 2026. Always confirm details against the official source above — this page is a summary, not legal advice.

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