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Status quo

AI has long had faces.
The only question is: which ones, and by what right.

Generative models train on billions of images. Who consented, under what conditions, who profits, rarely documented.

Where the images come from is rarely clear

AI faces can resemble real people

Who holds the rights is often unresolved

Who is liable is usually the company

Principles

What FaceLedger does not do.

We do not ask about skin color, origin, religion, sexual orientation or disability.

No beauty score and no hidden rankings. Search results appear in random order.

We only check that you are really you. Not whether you "fit". Anyone with a valid ID can sign up.

Companies see profiles only through targeted filters. Every profile view is logged and visible to you.

FaceLedger licenses faces for advertising. Erotic and pornographic content is fundamentally excluded. For everyone. No exceptions.

Why now

Why the gap is getting expensive now.

AI-generated advertising is everyday practice. From 2 August 2026 the EU AI Act requires it to be labelled: machine-readable, detectable, auditable. Every AI ad will carry a tag, and the next question is: whose face is that, and where is the consent?

Personality rights are fast-track matters. A preliminary injunction arrives within days: campaign stopped, booked media lost, material written off, re-production and new approvals. Afterwards the visual must disappear everywhere. Every forgotten pre-roll can trigger a fine of up to €250,000.

Older model contracts govern the use of a specific photo: print, web, billboard. Whether that photo may serve as AI training input was never part of the deal. Exactly this gap is now becoming the problem.

Whoever shows a person in advertising must prove consent. A face is also biometric data: the GDPR requires explicit consent and reverses the burden of proof. Without a documented contract, that proof is barely possible.

Since June 2025, New York requires written consent covering scope, pay and duration before a model's digital replica may be used. The EU AI Act follows in August 2026. Documented consent is becoming a requirement, not a courtesy.

The generators are trained on millions of real faces. Nobody can prove an output resembles no real person. The legal standard is recognizability, not intent. The company is liable even for unintended resemblance.

H&M creates digital twins of real models: nothing without explicit consent, the models own their twins and are paid per use. Licensed identity is becoming the standard. The only question is who supplies it.

Haltung. FaceLedger