Binding law — not yet in force or stayed
Disclose a synthetic performer in an advertisement (California SB 1050)
From 2027-01-01, it is unlawful for any person to create and cause to be published in an advertising medium an advertisement that prominently includes a synthetic performer (a digital figure, voice or representation created in whole or part with generative AI that gives the realistic impression of a human performer who is not an identifiable natural person) without a clear and conspicuous disclosure, worded substantially like 'this performance features a synthetic performer' or 'no human performer is depicted' (B&P 17610(a)-(c)). 'Prominently' covers a performer in the foreground demonstrating the product, voicing the narration, or reacting to it. Ads for expressive works using the performer consistently, and translation or accessibility-only uses, are excluded (17610(d)). A violation is a violation of B&P 17500 (17610(f)). Detect ad-generation code that adds an AI avatar, digital human or synthetic voice with no disclosure.
Trust and provenance not reviewed by a lawyer · audit-grade · source verified 4 Oct 2026 · release 2026.10.04.3
- Lane
- Binding law — not yet in force or stayed Enacted, not yet applying: applies from 1 Jan 2027
- Official source
- Cal. Bus. & Prof. Code 17610(b) · captured 4 Oct 2026 · anchor hash (SHA-256)
aba452574cc5…· 5 more anchors in the data release - Verification
- Quoted text found word for word in the captured official document (4 Oct 2026). Source last verified 4 Oct 2026: checked against the captured official document.
- Data release
- Data release 2026.10.04.3, data as of 4 Oct 2026, schema 0.3.10.
- Legal review
- Not reviewed by a lawyer. TwinEthos derived this rule from the official text it cites: treat it as research to check against that text; it is not legal advice. No TwinEthos rule has been legally reviewed yet. Open questions for counsel on this rule: 1.
- Audit standard
- Audit-grade: meets all 10 checks of the TwinEthos audit standard that apply to it. The audit standard is TwinEthos's own quality bar for provenance, dates, applicability, detectors, fixtures, remediation and licences; it is not a legal review.
- Detectors
1 detector (code pattern), experimental: written from the rule's text and not yet measured for precision on real code, so treat a hit as a lead to verify.
Known limits:
- Ads assembled in a video editor outside the repository
- Disclosures added by the ad platform
- The disclosure overlay may be applied by a rendering service or ad-server template in another file; check the export path. Avatars used for training videos or support, not advertising, are out of scope.
Who it applies to
- Duty falls on: any person
- Any person who creates and causes to be published in an advertising medium (broadcast, cable, online platform, streaming, digital ad network, publisher) an advertisement to consumers in California that prominently includes a generative-AI synthetic performer, including ad-generation tools that insert AI avatars, digital humans or synthetic voices. Applies from 2027-01-01.
- Not covered:
- Advertisements for expressive works (motion pictures, television, streaming content, documentaries, video games and similar works) where the synthetic performer is used consistently with the work (17610(d)(4))
- Advertisements in which generative AI is used solely for language translation of a human performer or other accessibility features (17610(d)(5))
- Whether it applies depends on facts outside the code; a person has to decide.
The guard to add
Add a clear 'synthetic performer' disclosure to every generated ad that features an AI avatar, presenter or human-like voice.
The ad-composition pipeline marks an ad as containing a synthetic performer whenever it inserts an AI avatar, digital human or synthetic voice; the renderer then overlays a legible disclosure ('This performance features a synthetic performer' / 'No human performer is depicted'; in Turkey a clear, distinguishable statement that AI is used), for the whole time the performer is on screen where required, and the export refuses an ad that is marked but undisclosed. Translation or accessibility-only uses are recorded as such.
Where it goes: 9 AI output handling, 1 application source code, 14 user-facing text.
What this provision adds:
- Word the disclosure substantially like 'this performance features a synthetic performer' or 'no human performer is depicted', clear and conspicuous for the medium, format and context.
Example (Python ad generator + avatar video API), before:
video = avatar_api.create_video(avatar_id=AVATAR, script=ad_script)
publish_ad(campaign, video)After:
DISCLOSURE = 'This performance features a synthetic performer'
video = avatar_api.create_video(avatar_id=AVATAR, script=ad_script)
video = overlay_caption(video, DISCLOSURE, whole_duration=True)
publish_ad(campaign, video, synthetic_performer=True)Control: An advertisement featuring an AI-generated synthetic performer or human-like digital character is published without a clear disclosure. The same guard addresses 3 items with binding law in 3 jurisdictions. Engineering guidance, not legal advice.
Rule id ca-sb1050.synthetic-performer-ad-disclosure · review status: primary source derived