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Law / United States / California

Digital Replica Likeness and Impersonation Law (SB 1111)

Cal. Civ. Code Section 3344; Cal. Penal Code Section 540 (SB 1111, Ch. 862, Stats. 2026)

An AI prohibited practices rule binding private bodies.

Obligation class
Prohibition, Consent

As of .

What it requires

  • Do not knowingly use another person's name, voice, signature, photograph, or likeness, including a digital replica of their voice or visual likeness, on products, merchandise, or goods, or for advertising or selling, without that person's prior consent, or the prior consent of a parent or legal guardian in the case of a minor
  • Do not use a digital replica with the intent to impersonate another person where false impersonation is an element of an offense, including the offenses in Penal Code sections 528.5, 529, and 530

These lines are LexLint's reading of the law's text, as of .

In the frameworks

NIST AI RMF
  • MAP 3.3Targeted application scope is specified and documented based on the system’s capability, established context, and AI system categorization.
NIST AI 600-1
MIT mitigations Draft
  • 1.5Safety Decision Frameworks
  • 3.3Access Management
NIST Privacy Framework
  • CT.PO-P1Policies, processes, and procedures for authorizing data processing (e.g., organizational decisions, individual consent), revoking authorizations, and maintaining authorizations are established and in place.
FINOS AIGF
ETSI EN 304 223
  • 5.1.2-1Business need and security risks written down and assessed before deciding to build an AI system.
  • 5.1.4-5End-users told which uses of the system are prohibited.

Our reading of where this law's duties sit in each framework. It never says that running a control meets the law. How we read a framework against the law

Identifiers refer to ETSI EN 304 223 V2.1.1 (2025-12), © ETSI 2025, all rights reserved. ETSI owns the standard; no ETSI text (titles or sentences) is reproduced here. The standard is free to download from ETSI.

What this law does

Drafted with AI

Drafted with AI from the cited sources under the direction of UnGovr staff. UnGovr holds editorial responsibility for this page. How this site is made

Research summary

Legal information, not legal advice. This is LexLint's own research summary of a public legal source, and it creates no attorney-client relationship. For decisions that matter, consult qualified counsel in the relevant jurisdiction. About LexLint

SB 1111 was chaptered on as Chapter 862 of the Statutes of 2026. Civil Code section 3344 makes a person who knowingly uses another's name, voice, signature, photograph, or likeness on products, merchandise, or goods, or for advertising or selling, without prior consent liable for the greater of $750 or the actual damages, plus the profits attributable to the use. SB 1111 provides that, for purposes of that section, a voice or likeness includes a digital replica.

A digital replica is a computer-generated, highly realistic electronic representation that is readily identifiable as the voice or visual likeness of an individual in which the actual individual either did not actually perform or appear, or did perform or appear but the fundamental character of the performance or appearance has been materially altered.

SB 1111 also removed the rebuttable presumption that failure to obtain an employee's consent was not a knowing use where the employee's photograph or likeness appears incidentally in an advertisement or other publication. New Penal Code section 540 provides that, for any provision of the Penal Code in which false impersonation of another is a required element, including Sections 528.5, 529, and 530, false impersonation includes the use of a digital replica with the intent to impersonate another.

When LexLint raises it

When your app profile says your app generates content with AI or processes voice recordings.

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