Model Release & Likeness Clearance Review
Your AI exposure isn't the release you signed. It's what you can't prove it covers.
Your model releases were written for photography. “All media now known or hereafter devised” is generally not sufficient to authorise a digital replica or an AI-generated derivative. Generative AI is now in the design and campaign pipeline at most brands that have announced an AI programme — and the releases, photographer contracts and stock licenses behind that pipeline all predate it.
New York's Fashion Workers Act requires separate, scoped consent for AI digital replicas. Statutory obligations do not flow down a supply chain the way contractual risk does — a release your agency signed in 2019 does not become compliant because your vendor says it is.
A structural and evidentiary review, not legal advice.
Consent is now a specified, separate document
The clearest example is New York. If you shoot, license or run campaigns that touch New York, the ground moved under your existing paperwork — and it moved before most brands put generative AI into production.
Under New York’s Fashion Workers Act (S9832), in effect since 19 June 2025, creating or using a model’s digital replica requires the model’s clear written consent, and that consent must specify scope, purpose, duration and the compensation payable for the use. Consent must be separate and explicit. Any prior power of attorney that purported to cover digital replicas ceased to be valid on that date. Routine photographic edits — colour correction, minor retouching, standard post-production — are excluded.
New York State Department of Labor guidance and contemporaneous practitioner analysis, retrieved 8 August 2026. Summarised here for orientation, not as legal advice.
Read that against a release drafted for a photoshoot and the gap is structural, not a drafting nicety: an omnibus “all media” grant specifies no scope, no duration and no separate compensation for replica use, because nobody was contemplating replica use when it was signed.
What the review examines
The same ten-point framework as the License Exposure Review, applied to likeness and personality rights rather than content licensing. Every point is rated Sound / Weak / Absent.
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Release scope against AI use
Does the release enumerate digital replica, synthetic derivative, training and inference-time use — or does it rely on an omnibus “all media now known or hereafter devised” grant?
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Separateness and specification of consent
Where separate written consent is required, does one exist? Does it state scope, purpose, duration and compensation, or is replica use folded into a general engagement term?
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Chain of consent through the supply chain
Agency, photographer, retoucher, production company, stock library, AI vendor. Where does the consent originate and does it actually reach the entity performing the generation?
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Photographer and stock license alignment
Do the image licenses underneath your campaign permit AI adaptation and derivative generation, or only reproduction and display?
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GenAI asset lineage
For assets already generated: which source images fed them, under which releases, and can you reconstruct that mapping if challenged?
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Revocation and withdrawal mechanics
If a model withdraws consent, what happens to assets already generated, models already fine-tuned, and campaigns already live? Is there a mechanism, or only a clause?
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Machine-readable reservation posture
What do your own systems publish about your imagery — robots.txt, TDMRep, RSL, terms of service — and does it match the position your contracts assert?
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Evidentiary survivability
The synthesis. If a model, a regulator or a counterparty challenged a specific generated asset, what precisely would you produce?
Start with an Exposure Scan.
One release or campaign, one counterparty, five working days, a written verdict on what your paperwork would actually support. €2,500, credited in full if you commission the fuller Review within 60 days.
A structural and evidentiary review, not legal advice. LicenseFoundry is a Netherlands-registered company; engagements are contracted from the Dutch entity.