SAG-AFTRA's AI and digital replica rules, contract by contract

September 27, 2026

How SAG-AFTRA's TV/Theatrical, Sound Recordings, Commercials and Interactive Media contracts handle consent and pay for digital replicas and AI.

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The short version

  • Across SAG-AFTRA's major contracts, producers need a performer's informed consent, tied to a reasonably specific description of use, to create or use a digital replica.
  • The 2026 TV/Theatrical Agreement, in effect from July 1, 2026 to June 30, 2030, tightens those rules and adds new limits on AI "synthetics."
  • These are collective bargaining agreements. They bind signatory employers for covered work, not the general public.

What the law does

Union contracts are not statutes, but for covered work they are enforceable, including through the union's grievance and arbitration process. State laws such as California's AB 2602 also treat a union agreement that expressly addresses digital replicas as a form of representation.

2026 TV/Theatrical Agreement (SAG-AFTRA and AMPTP). Building on the 2023 terms, the 2026 deal, according to the union's summary of the agreement:

  • Treats a replica made from footage already shot for the picture, without a scan, as an "employment-based digital replica," with all the same protections.
  • Limits "scripted" alterations to the script actually given to the performer on or before the date they performed the scene.
  • Sets the day performer rate as the minimum for using an "independently created" digital replica, with residuals where a human performer would earn them.
  • Requires consent to use a replica to dub a performance into another language, for pictures starting principal photography on or after July 1, 2027.
  • Bars using a minor's replica to depict nudity or simulated sex, including by aging them up or down.
  • Bars using a replica during a strike where consent is required and the performer could refuse to work.
  • Requires producers to secure replicas, limit access, and stay responsible after a transfer unless the union approves the transferee.
  • Requires an "articulable business reason" to ask for a scan.
  • On synthetics (AI-generated performers not based on a real person), producers agreed to a principle strongly favoring human performance, a notice and bargaining schedule, and not to use a synthetic in a human role unless it brings "significant additional value" compared with a human or a digital replica. The union can arbitrate for damages.
  • Requires notice to the union, and a meeting on request, when a producer licenses covered performances for training a public-facing commercial generative AI system.

2024 Sound Recordings Code. Ratified in April 2024, it provides that "artist," "singer" and "royalty artist" mean humans. It requires clear and conspicuous consent, with minimum compensation and details of intended use, before releasing a recording that uses a digital replica of an artist's voice.

2025 Commercials Contracts. Producers use a standard Digital Replica Rider. Performers consent separately to creating a replica and to specific uses listed in a table with a "reasonably specific description." Any change to intended uses must be in writing and signed by the performer, and performers can decline or modify the rider.

2025 Interactive Media (Video Game) Agreement. Ratified by members in July 2025, it requires informed consent and disclosure before a performer's digital replica is created or used, with compensation. Performers can suspend consent for generating new material during a strike.

Who it protects

SAG-AFTRA members and other performers engaged under these contracts by signatory producers, including actors, background actors, stunt performers, singers, recording artists, voice actors and on-camera commercial talent.

What it means for you

Actors and background actors: Read any digital replica consent separately from your deal memo. Under the 2026 terms, "no scan" replicas made from footage still count.

Recording artists and session singers: Digital voice replicas require clear, specific consent before release.

Commercial performers and agents: The Digital Replica Rider is where uses are defined. Blank tables limit what a producer can do.

Game performers: Check the replica disclosure and your right to suspend consent during a strike.

What it doesn't do

  • It doesn't cover non-union work, or work for producers that haven't signed the contract.
  • It doesn't stop third parties with no contract with you from making deepfakes. For that, look to state laws and, if enacted, the federal NO FAKES Act.
  • Some details depend on the full contract language, which is longer than any summary.

Status and key dates

  • April 30, 2024: 2024 Sound Recordings Code ratified.
  • 2025: Commercials Contracts ratified.
  • July 9, 2025: Interactive Media Agreement ratified (95.04% in favor).
  • June 4, 2026: Members ratified the 2026 TV/Theatrical contracts (91.42% in favor).
  • July 1, 2026 to June 30, 2030: Term of the 2026 TV/Theatrical contracts.

Frequently asked questions

Can a studio use my digital replica without my consent under SAG-AFTRA rules? For covered work, generally not beyond narrow uses consistent with how the work was scripted, performed and recorded. New uses require consent with a reasonably specific description.

What is a "synthetic" under the 2026 TV/Theatrical Agreement? A digital asset created through generative AI that appears to be a natural performer but is not recognizable as any identifiable person and is not voiced by one.

Do SAG-AFTRA's AI protections apply if I'm not in the union? They apply to work under the contract with signatory producers. For other work, your protections come from your own contract and state law.

What you can do

  • Ask for every digital replica consent as a separate document and keep a signed copy.
  • Check whether a project is a union job before agreeing to AI terms.
  • Contact SAG-AFTRA if a producer's request seems to go beyond the contract.

Royall helps you keep a record of what you have and haven't consented to.

Sources

Last verified: 2026-09-27

This is general information, not legal advice.

onwards,
The Royall team