Practical guide
How to use AI-generated images
without legal risk.
There is no single "AI image is legal" rule. Compliance is a sequence of decisions: which faces, on what terms, for which audiences, with what audit trail. This is the checklist a campaign needs to pass legal review.
1. Confirm the rights chain before you generate
The risk concentrates at the moment of identifiable resemblance, not at generation time. If the depicted likeness can be traced to a real person, you need their consent, and that consent has to be specific to commercial use, the scope of the campaign, and the medium. Generic stock-image releases do not cover AI-generated likeness.
2. Separate training rights from output rights
These are two different licenses. Output rights govern whether a specific generated image can be published. Training rights govern whether a face can be used to fine-tune or condition a model. Most brands need only output rights; they should never accidentally pay for training rights they do not use, and they should never assume output rights cover training.
3. Configure the license per campaign
A real license has a duration, a geography, a medium list, and an industry-exclusion list. "Worldwide forever" licenses are expensive and rarely necessary. Configure the smallest license that fits the campaign, DACH, 12 months, print + social, exclude politics and pharma, and renew when needed. This also reduces what the depicted person is asked to consent to, which improves consent quality.
4. Maintain a per-use audit trail
Every published asset should map to a license ID and a documented consent record. When a complaint arrives, the answer is a file, not a discussion. Audit trails also matter under GDPR Art. 30 (records of processing) and the EU AI Act transparency obligations.
5. Build in a revocation path
Consent in EU privacy law is revocable. A license that ignores this is not actually compliant. The right pattern is: revocation is always available, active deployments enter a defined sunset window (so the campaign is not yanked off-air mid-flight), no new uses are permitted after revocation. This is fair to the depicted person and predictable for the brand.
Every AI-generated face is a legal risk. Unless it is licensed.
FAQ
Frequently asked.
Can I use stock-photo licenses for AI-generated content?+
Generally no. Stock licenses cover the use of a specific image file, not the right to use a depicted person's likeness in newly generated content. AI-generated content needs a separate license focused on the likeness, not the original photograph.
Do I need rights if the AI face is "fictional"?+
If you cannot guarantee non-resemblance to any real person, you are exposed. Fictional generation is a defense in theory; recognizability is the test in practice. Licensed identities replace this open question with a closed contract.
What about images generated for internal use only?+
Personality rights and GDPR apply to internal commercial use as well. The damages may be smaller, but the legal exposure exists. Treat internal moodboards and pitch decks as you would any commercial use.
How does FaceLedger handle this?+
FaceLedger is the licensing layer. Each license is configured per campaign, duration, geography, medium, sensitive-industry exclusions, with consent documented per license, output and training rights separated by default, and an audit trail per use.
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