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PATCH 2026.11.14

SAG-AFTRA Video Game AI Rules: When Actors’ Digital Likenesses Can Be Used

By VGSources Team 9 min read

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The 2025 SAG-AFTRA Interactive Media Agreement gives covered video game performers specific protections when an employer creates or uses a digital replica of their voice or likeness. In general, the agreement requires clear, separately signed or initialed written consent tied to a reasonably specific description of the intended use, and it sets minimum compensation rules for covered replica work. Those protections have limits: they apply according to the agreement covering the engagement, the kind of replica and use, and defined exceptions. They do not create a universal right to revoke any consent at any time.

The agreement took effect immediately after SAG-AFTRA members ratified it on July 9, 2025. The union reported a ratification vote of 95.04% to 4.96%. Its 2025 Interactive Media Agreement materials and the union’s February 2026 Digital Replicas and Consent bulletin describe how the negotiated rules work.

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What does the SAG-AFTRA video game agreement protect?

The agreement addresses how covered employers may create and use defined digital replicas of performers for new performances, including AI-generated voice performances and certain visual performances. Its central safeguards are advance, specific consent; compensation for the covered work and uses; restrictions on using a replica for a different program or purpose; and limited ways to suspend consent in strike circumstances.

These protections are contractual, not a blanket rule for every performer or game. SAG-AFTRA says the 2025 agreement covers named game producers, while tiered-budget I-IMA, independent localization, student, and game-jam agreements remain separate agreements with their own terms. A performer’s particular coverage therefore depends on the agreement governing the engagement and the work being performed.

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The union’s broader position, stated in March 2023, is that rights to digitally simulate a performer to create new performances must be bargained with the union; it also says recorded-performance uses and reuses are governed by collectively bargained provisions, including consent and compensation. That is SAG-AFTRA’s stated position, not a separate legal ruling. The 2025 agreement supplies the operative negotiated terms for engagements it covers.

What counts as a digital replica under the agreement?

The contract uses distinct categories for a “Digital Replica” and an “Independently Created Digital Replica” (ICDR). They should not be treated as interchangeable labels: each has its own definition and conditions, although the union’s 2026 bulletin says the consent requirements apply to both, subject to listed ICDR exceptions.

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A Vocal Digital Replica is an algorithmic system capable of generating new vocal performances in the voice of a specific principal performer. The agreement’s definition ties the replica to digital technology, primarily to the performer’s IMA-covered vocal performances, and to new performances that the performer did not previously record and that are made in lieu of the performer. The voice must be objectively identifiable as that performer’s, including when the performer is identified through a character role.

A Visual Digital Replica concerns generating new visual performances of a specific principal performer in particular roles in scripted cinematic content. The performances must not have been previously recorded by the performer, must be made in lieu of that performer, and must be objectively identifiable as the performer, including in character.

An ICDR is separately defined. Broadly, it can involve data or audiovisual performances outside the IMA, or prompting a generative AI system with a principal performer’s name, subject to detailed employment, role, identifiability, and other conditions in the agreement. Whether a particular asset or AI process falls into that category requires the full contract definitions and the facts of the engagement—not simply the fact that AI was involved.

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Does the contract cover voice clones and visual likenesses in the same way?

No. The agreement’s treatment depends on the type of output and where it appears. The union says vocal replica coverage reaches both in-game and cinematic material, while the visual Digital Replica provisions address scripted cinematic scenes. SAG-AFTRA also says visual in-game material may qualify for a Secondary Performance Payment; that is different from assuming every visual in-game use is covered by the cinematic visual-replica rules.

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Identifiability matters for both voice and visual replicas: SAG-AFTRA describes coverage in terms of output objectively identifiable as a specific performer, including in character. This is narrower than saying that any synthetic voice, generic character animation, or AI-generated asset automatically triggers the same replica terms. The applicable definition, source material, role, and use all matter.

Movement performers’ work on a volume illustrates another coverage boundary. SAG-AFTRA’s position is that this work is performance covered by the contract, while the employer bargaining group reserves a different position depending on the type of performance. The 2025 agreement preserves that disagreement, so coverage should not be presented as settled for every volume or motion-capture scenario.

What consent must a covered employer obtain?

For covered Digital Replicas and ICDRs, consent must be written clearly and conspicuously, separately signed, checked, or initialed—or provided in a separately signed writing—and limited by a reasonably specific description of intended use. A broad, buried provision that does not identify the contemplated use is not the consent process described in the union’s summary of the agreement.

The agreement summary says the use description must include material project information. Depending on the engagement, those details can include:

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  • Project code name and prior intellectual property, and whether the performer is reprising a role.
  • Genre and whether the work requires profanity or violent or sexual content.
  • Stunts, role length, unusual terminology, and memorization or prompting devices.
  • Whether real-time generation is planned.

The purpose of specificity is practical as well as formal: a performer can assess the assignment and the proposed replica use before agreeing. The contract summary states: “Performer’s consent to the creation and use of their Digital Replica must be: (1) Set forth in writing in a clear and conspicuous manner; (2) Separately signed or initialed; (3) Subject to a ‘reasonably specific description of intended use’…” The full 2025 agreement summary provides the union’s published description of the terms.

Consent is not a blank check for an employer to change the project or use later. SAG-AFTRA’s FAQ says that if the replica use no longer fits the reasonably specific description originally supplied, consent is invalidated and the use is no longer permitted under the agreement. The question is whether the actual use remains within the agreed description, not whether the performer dislikes the result after the fact.

Can a studio use a replica in another game or project?

Generally, a new use outside the Interactive Program for which the replica was created requires consent before that additional use. The agreement does not permit an employer to obtain that additional-use consent at initial employment as a general advance waiver.

There is a defined franchise exception. For franchise games, consent can be obtained at first employment if the franchise use is reasonably specifically described and compensation is agreed for each Interactive Program, subject to applicable minimums. This is not permission for unspecified reuse across any future project; the franchise, intended use, and payment arrangement must meet the contract’s conditions.

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Other provisions are category-specific. The union bulletin notes that reuse in a linear program is subject to the agreement’s reuse provisions. It also identifies a pre-production exception for certain scratch or previz material where the performer has been employed on a game in the franchise. ICDRs have listed First Amendment and third-party authorized-licensing exceptions. These exceptions should be read in their own contractual contexts rather than generalized to every Digital Replica or every use.

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How does the agreement pay performers for replica work?

The agreement sets different minimums for vocal and visual replicas, and the applicable formula depends on the work. Time spent providing covered services to create a Digital Replica counts as compensated work time and is subject to IMA working conditions. The figures below are contract formulas, not a universal dollar amount; the actual scale depends on the applicable minimums and engagement.

Covered use Minimum payment method described in the agreement
Vocal Digital Replica Limited Integration payment, described as a session fee for each 300 lines generated. A line averages ten words or one individual sound, such as a monster or effort sound.
Visual Digital Replica At least scale for the number of production days the employer estimates in good faith would have been required if the performer had worked in person.
Both vocal and visual forms At least the greater of the applicable vocal or visual amounts.
Real-time generation of dialogue that was not pre-generated At least 750% of the applicable minimum scale, according to SAG-AFTRA’s February 2026 bulletin.
Digital Replica used to generate pre-production material At least one scale payment per Interactive Program, as stated in the agreement summary.

The 750% rate is specific to qualifying real-time generation of dialogue that was not pre-generated; it should not be applied to every replica use. Similarly, the 300-line payment method is for vocal replica generation, while the visual formula is based on estimated in-person production days. When both types of replica are used, the summary says the minimum is the greater of the two amounts—not automatically their sum.

The agreement also raised general performer compensation by 15.17% compounded upon ratification, with further 3% compounded increases in November 2025, November 2026, and November 2027, according to SAG-AFTRA. Those general increases are separate from the digital-replica payment formulas above. They should not be substituted for the specific minimums governing replica creation or use.

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Can an actor revoke or suspend consent?

Not as a general anytime right under the agreement. Consent to generate new material using a Digital Replica is automatically suspended during a strike for an Interactive Program subject to that strike. For other Interactive Programs, and for specified pre-production uses, a performer may suspend consent by giving written notice to the employer.

SAG-AFTRA’s FAQ cautions that, absent separately negotiated conditions for suspending consent, a strike is the only instance in which a performer may suspend consent, except where the agreement automatically suspends it. This is narrower than an unrestricted right to withdraw consent at will after signing.

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That limit does not eliminate the requirement to stay within the original consent. If use departs from the reasonably specific description, SAG-AFTRA says the consent is invalidated for that changed use. In practice, a performer assessing a concern should distinguish a request to stop a use that has changed from an attempt to withdraw permission for a use that remains within the agreed scope.

How can performers check coverage or raise a concern?

Start with the agreement covering the engagement, the consent document, and the described project and replica use. Confirm whether the work is governed by the 2025 Interactive Media Agreement or a separate agreement, whether the replica is categorized as a Digital Replica or ICDR, and whether the output and intended use fit the relevant definition. A contract label alone may not resolve disputed coverage, especially for movement performers or assets used in different contexts.

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SAG-AFTRA says members receive usage reports for Digital Replicas to help identify potential noncompliance. The union also describes claims, arbitration, and requests for information under the National Labor Relations Act as enforcement options. Members with a specific Interactive Agreement question can contact the union’s Interactive department at [email protected] or (323) 549-6815, as listed in the February 2026 bulletin. A case-specific concern may require review of the actual contract and engagement terms.

For actors, the central protection is therefore not simply that a company must ask before using “AI.” It is a defined, documented process: classify the replica and use, obtain consent with a reasonably specific description, pay the applicable minimum, and stay within the authorized scope—subject to the agreement’s exceptions and the coverage of the individual engagement.

Frequently Asked Questions

Does the SAG-AFTRA video game agreement cover games made outside the United States?

The materials summarized here identify the covered agreement and separate agreement categories but do not establish a general geographic rule for every production. For an international engagement, the relevant question is which union agreement governs that performer’s services and whether the employer and work fall within its coverage.

What should an actor keep after signing a digital-replica consent?

Keep the signed consent and the project description or other disclosure provided with it, including any written notice about real-time generation. Those records help establish what use was actually described and authorized if a later use is disputed.

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Does the 2025 agreement mean every AI-generated game voice needs SAG-AFTRA consent?

No universal conclusion follows from the agreement: its provisions apply to covered performers, defined replica categories, and covered engagements. A synthetic voice that is not objectively identifiable as a specific performer, or work under a different agreement, may raise different contractual questions.

Where can a SAG-AFTRA member get help with a video game replica issue?

The union’s February 2026 Interactive bulletin lists [email protected] and (323) 549-6815 for the Interactive department. Members should have the agreement, consent paperwork, and relevant usage information available when asking about a specific case.

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