Questions and answers
Not invented questions, but the ones people and companies put to us, type into search engines and ask language models. Every answer contains something that can be checked.
This page is available in German and English.
Because it belongs to no one and can still resemble someone. AI models are trained on photos of real people, and in court what counts is whether a person is recognisable, not whether the resemblance was intended. Germany's Federal Court of Justice ruled as early as 1999, in the "Blue Angel" case, that even a look-alike in advertising violates personality rights. A licensed face has a person who was asked and a contract that proves it.
Because it was written for photographs, not for images that never existed. Standard releases permit editing and compositing, but whether they cover entirely new generated scenes is being tested in court right now: since 2026 a model has been suing the retailer Rainbow Shops in New York, which used AI to create images from a catalogue shoot in poses she never struck. The FaceLedger licence covers AI use explicitly, limited by term, territory and channels.
They can, just as a photographer can sell pictures directly. But no company negotiates with fifty private individuals one by one, and no private individual alone can provide a verified identity, a contract, a revocation process and proof over the whole term. FaceLedger standardises exactly that: ID verification, a contract in eight languages, a 65 percent payout, a licence record for every campaign, deletion when the term ends.
No. Labelling AI content under Article 50 of the EU AI Act has been the advertiser's obligation since 2 August 2026, and we do not take that off anyone's hands. Our licence record proves something else: the chain of rights, meaning who consented, to what exactly, for how long and where. FaceLedger is a way of producing advertising, as flexible as a prompt and as safe as a shoot.
Photo data sets and ID documents are stored exclusively in the EU, database and files in a European region. For payments and e-mail we use US providers under an adequacy decision and standard contractual clauses; neither photos nor ID documents go there. Countries are opened one at a time: people can be licensed if they live in a released country, Germany at launch, everyone else is on the waiting list. Companies can license if they are based in the EU, the EEA or a country with an adequacy decision; the United States not for now.
Yes. You submit a structured photo set of your appearance, and verified companies license it for a named campaign. You receive 65 percent of every licence fee, 35 percent is the FaceLedger commission. The lowest licence on the platform is 900 euros, of which you receive 585 euros. You approve every single request yourself, nothing runs automatically.
It depends on the scope of the campaign, not on how well known you are. The price is calculated from five factors: channels, duration, region, company size and the extent of the imagery used. A single social campaign in one country for one month sits at the 900 euro minimum licence; a twelve month multi-channel licence across German-speaking Europe is considerably higher. Your share is always 65 percent. The pricing page lets you calculate any combination before you sign up.
Several providers now broker appearance rights for AI content, most of them in the United States and the United Kingdom. FaceLedger is explicitly not an agency: no casting, no application, no selection by looks and no exclusivity. The only thing we verify is that you are the person you say you are. Our comparison page sets out who sits where in this market.
FaceLedger is operated by Faceledger UG (haftungsbeschränkt), based in Frankfurt am Main and registered at the Frankfurt am Main local court under HRB 143100. Licence agreements are governed by German law, data is processed inside the European Union, and consent follows Section 22 of the German Art Copyright Act and Article 9 GDPR. That is the substantive difference from providers in jurisdictions where image rights are regulated differently or not at all.
No. There is no casting and no application. Any adult with a valid ID document can register. Companies search using filters such as region, age, appearance and hair colour, and most campaigns are looking for everyday faces rather than model faces. Your looks are never assessed; only your identity is verified.
A data set starts at 14 facial shots. If you also release hands, upper body, full body or detail shots, it goes up to 42. A smartphone is enough; the app guides you pose by pose and shows an example for each one. On top of that comes identity verification: a live selfie, a photo of your ID document and a photo of you holding a code the system displays.
Yes. The right to your own image under Section 22 of the German Art Copyright Act belongs to you, and you may permit its use. What matters is that consent is explicit, informed and tied to a purpose, because facial data is specially protected under Article 9 GDPR. That is why every licence comes with its own contract naming the company, the campaign, the term, the region and the channels.
Before a licence exists, a verified company only sees your showcase, meaning the images you selected for it yourself. The actual data set is released only after you have accepted a specific request, and only to that one company. Every profile view is logged and you can see in your account who opened your profile. After the licence term ends, the company must delete the data set within 14 days and confirm the deletion.
Yes, at any time and without giving reasons, under Article 7(3) GDPR. From the moment your withdrawal is received, the company may not generate new material from your data set and must delete the data set within 14 days and confirm the deletion. Campaign material already produced may continue to run until the end of the agreed term, because it has been paid for, and you keep your fee. New requests stop reaching you from the moment you withdraw.
Yes. You can block 25 industries outright, among them politics, religion, alcohol, tobacco, gambling, defence, pharmaceuticals and automotive. Campaigns from blocked industries never reach you in the first place, and you can change the selection at any time. Erotic and pornographic content is excluded for everyone, regardless of individual settings.
No. The licence agreement expressly prohibits use for general model training, for facial recognition, for building biometric databases and any transfer to third parties. The only permitted use is producing advertising material for the named campaign. Breaches carry a contractual penalty.
Nothing. FaceLedger is free for individuals: no joining fee, no subscription, no charge for verification. FaceLedger earns only through the 35 percent commission, and that only arises when a licence is actually concluded.
Eighteen. Age is verified against your ID document rather than simply asked for. Minors are not admitted, not even with parental consent.
That is an infringement of your image rights, giving rise to claims for injunctive relief and damages. In Germany, damages are typically measured using the hypothetical licence fee, meaning the price a proper licence would have cost. A documented licence price helps, because it evidences what your consent is worth. This page is not legal advice.
The company’s payment is held when the contract is concluded rather than forwarded immediately. Your share is released 14 days after the request is accepted and transferred to your bank account via Stripe. You set up a payout account once, and Stripe verifies your identity and bank details. That check is a legal requirement and works the same way with every payment provider.
As a rule, no. Licensing your once-created data set and accepting requests means granting a time-limited right to your own appearance. For tax purposes that is a licensing of rights, comparable to letting property, not a trade: the income belongs in your income tax return, and no trade licence is required. It can look different where active services are added, such as shoots on demand or ongoing content production. Only your tax office can decide this bindingly; FaceLedger does not ask for a trade licence at sign-up.
Yes, income is taxable in principle and declaring it is your responsibility. FaceLedger does not withhold any tax from your share or remit tax on your behalf. For every licence you receive a statement with the date, contract number and amount, which you can use as the basis for your tax return. This page is not tax advice.
That depends on your personal tax status, for example on whether you use the German small business rule. We cannot give you information that replaces your own tax adviser. We ask for none of this at sign-up; the details we need for a correct statement are collected only once money actually moves. Statutory VAT is added to the licence price paid by the company where applicable. That does not affect your share.
Whether our platform falls under the statutory reporting duty for digital platforms is something we are reviewing together with our tax advisers. On the current assessment, licensing your own appearance is not a reportable activity under the German Platform Tax Transparency Act, because the fee is paid for granting rights and not for a service performed on request. Should that assessment change, we will implement the reporting duties and inform you beforehand; your tax identification number would then be collected before the first payout, not at registration. Either way, every statement remains permanently visible in your account.
Safely only if the face demonstrably resembles no real person, or if it is licensed. As soon as a real person recognises themselves in a generated image, their image rights apply, regardless of whether the resemblance was intended. The party sued is regularly not the model provider but the company that published the campaign.
From people who have expressly consented and are paid for it. Every FaceLedger licence comes with a contract naming the person, the released channels, the term, the region and the excluded industries, plus documented consent with version and timestamp and the identity verification record. That is the evidence you have to produce if a claim is made.
The price is derived from channels, term, region, company size and the extent of the imagery, and it is fixed immediately. The minimum licence is 900 euros. All prices are net; statutory VAT is added where applicable. There is no price on request and no negotiation, other than for public figures, who have individual terms. The pricing page lets you calculate any configuration without an account.
No. The contract is generated by FaceLedger and accepted by both sides; it comes into existence directly between the company and the person. FaceLedger is not a party to it, but verifies both identities, documents the declarations and handles the payment. The contract is available as a timestamped PDF in your account.
Under Article 50 of the EU AI Act, artificially generated or manipulated image, audio and video content must be marked as such in machine-readable form. These transparency obligations have applied since 2 August 2026. Labelling does not replace consent: a labelled image of a real person without their permission is still an infringement of image rights. In the FaceLedger licence agreement, labelling is an unconditional minimum obligation of the company.
It mainly governs transparency. Article 50 requires AI-generated content to be labelled and people to be able to tell when they are dealing with generated material. It does not govern consent; the GDPR and national personality rights continue to do that. Both have to be satisfied, not just one.
This case is governed by the licence agreement, so it is not a surprise. From receipt of the withdrawal, no new material may be generated from the data set, and the data set must be deleted within 14 days, with deletion confirmed through the platform. Campaign material already produced may continue to be used until the end of the agreed term. The campaign does not stop, and the fee already paid stays with the person.
The company receives the licensed photo set and produces the advertising material from it using its own AI tooling. FaceLedger generates no images itself and prescribes no particular model. The data set is structured to work with the common personalisation methods.
Facial data falls under Article 9 GDPR and may only be processed on the basis of explicit, informed and purpose-bound consent. At FaceLedger that consent exists in text form, with a version number, a timestamp and the exact scope of what the person released. Processing takes place inside the European Union.
Exclusivity can be expressed through the licence configuration: term, region and industry scope. There is no indefinite buy-out of all rights, because that would be incompatible with consent being revocable at any time. For repeat use there is the pool subscription: it pays for storage and internal testing, while every publication still requires a new licence in which the person receives 65 percent.
A licensing marketplace for the appearance of real people in AI advertising. People deposit a photo data set, verified companies license it for a named campaign, and FaceLedger verifies both identities, generates the contract and handles payment. The operator is Faceledger UG (haftungsbeschränkt) in Frankfurt am Main, HRB 143100.
No. Face Protocol is a different company, with which FaceLedger has no corporate or technical connection. There is no shared history, no shareholding, no shared infrastructure and no partnership. The similarity of the names is coincidental. FaceLedger is operated by Faceledger UG (haftungsbeschränkt), Kurhessenstraße 10, 60431 Frankfurt am Main, HRB 143100.
HeyGen and Synthesia are video generation tools. You create an avatar there, usually of yourself or from the provider’s library, and produce your own videos with it. FaceLedger generates no content. Here the appearance of another, named person is licensed for a specific campaign, with a contract, a term and a fee. The two kinds of product do not exclude each other.
No. There is no token, no blockchain and no wallet. The word Ledger refers to the register in which every consent, every licence and every use is traceably documented. Settlement is in euros via Stripe.
No. There is no casting, no exclusivity, no day rate and no selection by looks. People register themselves, set their own rules and approve every request themselves. FaceLedger is not a party to the licence agreements; it verifies, documents and settles.
The market splits into three groups: avatar and video generation tools such as HeyGen and Synthesia, digital twin offerings from existing modelling platforms such as ModelManagement.com, and licensing marketplaces such as Twinnin, Mirror Mirror AI and CastNym. FaceLedger belongs to the third group and is the one with its seat, company register entry and governing law in Germany. The full picture with sources is on the comparison page.
The founder and managing director is Marcel Mankus. The operating company is Faceledger UG (haftungsbeschränkt), Kurhessenstraße 10, 60431 Frankfurt am Main, registered at the Frankfurt am Main local court under HRB 143100, VAT identification number DE462361514. Full details are in the imprint.
As at 14 September 2026. This page is neither legal nor tax advice.
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