Spotlight's AI Statement: A Guide for Actors
Spotlight put out a statement last week about a job on the platform that uses AI-driven tools. It asks performers to understand how the technology is being applied before they submit, so this is my response to that, setting out what it involves and helping actors navigate the current state of AI castings.
Before I start, this area is changing quickly, both in what the technology can do and in what the Government is planning to do about it. What follows is a guide to help you ask better questions about a specific job. If you're looking at a contract, take it to your agent or to Equity.
If you are unrepresented, I'll say the most important bit first! This is all so new that if you read the job and something about it doesn't sit right, you're allowed to skip it. Missing one casting is not the end of the world, especially if that casting could have longer term consequences for your career.
What was all the fuss about?
The casting that prompted the statement asked actors to send a selfie. The advert itself, including the voice and the movement, would then be AI generated. The terms covered usage and a buyout.
Why this is a step change in how actors think about AI
Most of the current AI advice is written for a film or TV set. You turn up, you're asked to jump in a scanner, and the scan gets used for crowd work or a digital double later. That's what a lot of the Equity guidance is built around, and it's good guidance.
This particular job works differently, and it's the first of its kind I've seen come through on Spotlight. Most commercial work involving AI still has you performing, with the technology used on the material afterwards.
Here there's no performance at all. You send a selfie (or are photographed), and a system generates the voice, the movement and the finished advert from it. The tool makes the output from your photo.
This could impact your rights. Performers' rights under UK law attach to a performance you gave. If you never gave a performance, and what you handed over was a selfie, then as I understand it those rights may not engage in any meaningful way.
What you are doing is licensing your image and your data, which is a contract question and a data protection question rather than a performers' rights question. So the usual reassurance, that you're covered because you're a performer, may not hold on this kind of job.
The questions that now need answering before you submit to an AI casting
What exactly are they taking from me, and in what form. A selfie, other stills, video, voice, a scan, or material I already have online.
Is my material being used to train a model, or only processed once to make this specific piece of work. These are very different things and the fee should reflect that.
If a model or dataset is created from me, who holds it, where is it stored, and when is it deleted.
Is the finished output limited to this campaign, this client, this territory and this time period, or is it open-ended.
What am I being paid for. Is there a fee for supplying the material, and a separate fee for the usage, or is the whole thing a single buyout.
What can the generated version of me be made to do. What I appear to say, how my body looks, what I'm wearing, and whether I can see the output before it goes live.
The last one isn't a contract question at all. If the system generates the voice and the movement, you have handed over every decision an actor normally makes. How you sound, how you move, how you react. None of it is yours. Your craft isn't in the finished advert at all. What's out there is whatever the tool produced using your face, and you have no say in whether it's any good or whether it's something you'd want a casting director or anyone to see. So the final question is, are you ok with that?
Why performers in some European countries are better protected than we are
It comes down to what the law already says. Several European countries start from a position we have never had, which is that your likeness belongs to you.
Germany is the clearest example. It has long-established personality protection through the right to one's own image, which generally prevents the publication or commercial use of someone's likeness without their consent. Those rights have been part of German civil law for decades, so they pre-date AI entirely.
Detailed AI provisions are now circulating in the German market, applied as standard across work rather than negotiated job by job. They separate two things completely. Ordinary post-production using AI, so retouching, colour correction, lighting and format adjustments, needs no extra consent, because the material is left essentially as it was. Anything generative, where new images or audio are created from the performer's material, always needs express written consent. That includes using a performer's photo as a reference image, and using it for training.
The sort of terms being written include:
Purpose limitation. The material, and any model built from it, may only be used for the agreed purpose, the named end client, and the agreed period.
Training only on systems the client controls, with a specific prohibition on anything that exposes the material to an unknown public.
A fee structure split in two. One fee for supplying the material, and a separate fee for the usage rights, which govern how long, how many outputs, and where they can be published.
A ban on defamatory, discriminatory, pornographic or violent depictions, and written consent required before changing body dimensions, state of dress, or posture.
No creating new artificial people out of a performer's training data.
Secure storage, deletion after a set period, and earlier deletion on request.
A penalty for breach, set as a multiple of the total fee.
If you are applying for a commercial shooting in Germany, German personality rights protect the person rather than the citizen, so a UK actor working there is generally in the same position as a German performer. Always check which country's law your contract says applies.
In the UK there is no standalone image right. You have to piece protection together from intellectual property, contract, data protection and common law, none of which was written for what AI can now do. Here, nothing is given to you automatically. Anything you want protected, you have to ask for.
Denmark is worth watching too. A bill has been proposed there that would give individuals copyright over their own physical likeness, including face, body and voice.
Where UK law has got to
In March, the Government published its report on copyright and AI and accepted there's a gap. It acknowledged that AI makes it easy to create digital replicas of someone's voice or face, that existing protections don't cover every situation where that happens without consent, and that responses showed no single view on what enhanced protection should look like. It promised a further consultation over the summer on digital replica harms and whether to create a personality right.
That consultation hasn't appeared. The minister who committed to a summer timetable has since lost her job in a departmental reorganisation following a change of Prime Minister.
The pressure has gone up in the meantime. On 28 August, more than 80 performers including Nicola Coughlan, Hugh Bonneville, Matt Lucas and Siobhán McSweeney backed the Save Our Voices Now campaign, started by performer Peter Caulfield and audiobook narrator Alice Sockett, asking Parliament to make ownership of your own voice a statutory right. The letter went to the Prime Minister, and the ask is deliberately narrow, a statutory right over the use of your voice held by every person rather than only by working performers. The petition is on the Government's own website and still open if you want to sign it.
The Government's response so far is that it values human creators and has announced it will consult on how to address these harms while protecting legitimate innovation.
The position today is the same one I wrote about in July. Contract is still your strongest protection, because there isn't much else in place yet!
Where I stand on this
I don't think this particular job is acting. A job that takes a selfie and generates everything else isn't casting a performer, it's sourcing a face. The skill you've trained for isn't being used and isn't being paid for.
I also don't think these castings are going away. They're cheap and they're quick, and brands will be cutting ad budgets as costs rise. My guess is that the selfie stage disappears too, once the tools no longer need a real face to start from, and low-budget ads that run on volume stop involving actors at all.
That said, it's your career and your call. While these ads are still using actors, some people will look at the fee and the terms and decide it's worth it. What I would ask is that you go in knowing what you're agreeing to.
Written September 2026. This area is moving quickly, so do check the current position before relying on anything here. For practical, up-to-date union guidance on AI including contracts, read Equity's AI Toolkit for performers: equity.org.uk
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