Washington AI Likeness Law: June 10, 2026 Deadline — Compliance Checklist

June 10, 2026 is 32 days away. Washington's AI likeness and deepfake law takes effect that date. Here is what you need to check before then.

What the Law Prohibits

Washington's law creates three categories of prohibited conduct:

The law is enforceable by the person depicted (private right of action) and by the Washington AG.

Who Is Liable

Liability attaches to both creators and distributors:

• Creator — the person or entity that generates the AI content
• Distributor — the platform, service, or individual that shares, hosts, or transmits the AI content

If your platform allows users to generate or share AI-generated content depicting real people, you have potential exposure unless you have adequate consent mechanisms and moderation.

Which Tools Trigger Compliance Risk

Audit your tech stack for anything that falls into these categories:

What Consent Looks Like

Valid consent under Washington's law is:

• Written — oral consent is insufficient for commercial uses
• Specific — consent to use a person's likeness in one context does not transfer to other contexts
• Revocable — the person can withdraw consent, and continued use after withdrawal violates the law
• Informed — the person must understand what their likeness will be used for

For your own employees or contractors who appear in AI-generated content (product demos, training videos, avatars), you need signed consent that specifically covers AI-generated uses.

Platform Obligations

If you operate a platform where users can create AI content:

• Terms of Service — prohibit users from creating AI content of real people without consent
• Reporting mechanism — provide a way for individuals to report unauthorized AI depictions of themselves
• Takedown process — have a documented process for removing reported violations within a reasonable timeframe
• Content moderation — implement screening for AI-generated NCII (several third-party detection tools exist)

Compliance Checklist Before June 10, 2026

• 1. Audit AI tools — list every AI tool in your stack that can generate, clone, or manipulate human voice, face, body, or likeness
• 2. Identify real-person use cases — for each tool, identify where you use or allow use of real people's likenesses (not fictional characters)
• 3. Confirm consent documentation — for every real person whose likeness is used in AI-generated content, verify you have written consent covering that specific use
• 4. Terminate non-consented uses — if you are using a real person's voice or likeness without documented consent, stop before June 10
• 5. Update ToS and user policies — if your platform allows user-generated AI content, add explicit prohibition on non-consented likeness use
• 6. Implement takedown process — create a process for handling reports of unauthorized AI depictions before the law takes effect
• 7. Train content and product teams — anyone who creates marketing, demo, or training content using AI tools needs to understand the consent requirement
• 8. Review vendor agreements — if you use a vendor to create AI-generated content for you, confirm their consent practices and ensure their indemnification covers you for Washington-law violations

Key Dates

Penalties

The person depicted can sue for:

• Actual damages
• Statutory damages per violation
• Attorney's fees and costs
• Injunctive relief (court order requiring the content to be removed)

There is no cure period in the private right of action — once the law takes effect, violations are immediately actionable.

Sources: Washington State Legislature, Governor Ferguson's office, enacted bill text. This article reflects the law as signed; consult counsel for advice specific to your situation.