After article 13: what an actor can do today.

What article 13 was, and what changed

Article 13 was a clause in the draft royal decree that updates working conditions for artists under the Estatuto del Artista. It would have set rules for how generative AI can use an actor's voice, image and work.

AISGE, the Spanish collecting society for actors and dancers, campaigned against it. Its argument: this belongs in intellectual property law, not in a labour decree. On 8 July 2026 its director general wrote that, after a critical report from the Consejo de Estado, the Government agreed to remove the article from the final text. The final text was published as Royal Decree 607/2026 in the BOE on 25 July 2026, without article 13, and takes effect on 25 May 2027.

He also wrote that the actor is as unprotected against generative AI as the week before, and that the legal gap is still there. So the steps below rely on rules that already exist.

Step 1: Read the contract before you sign it

Look for any line that lets the producer or client use your voice, face or recording for more than the job at hand. Under the Intellectual Property Law (LPI), each authorisation to record, reproduce or make available a performance must be in writing (arts. 106 to 108).

Dubbing actors already have a model. PASAVE, the Spanish platform of voice-actor associations, publishes a clause that bars using the recorded voice to feed, train or simulate AI for any purpose other than the one production named in the contract. You can ask for the same wording.

If you work under an employment or service contract, the employer gets the reproduction and public communication rights that follow from the contract, unless you agree otherwise (LPI art. 110). So agree otherwise, in writing.

The LPI also says that dubbing your performance into your own language needs your express authorisation (art. 113.2). Whether that covers AI dubbing has not been tested in court, as far as we found.

Step 2: Ask your collecting society what it has done for you

AISGE and AIE collect the fair pay that performers keep by law after they transfer rights to a producer (LPI art. 108). They are also where the sector's AI position is being set.

At its general assembly on 5 June 2026, AISGE approved a general reservation of rights against the text and data mining exception for generative AI (article 4 of the 2019 EU copyright Directive). In plain words, it is an opt-out from AI training for the performances of its members.

Ask your society three things: are you a member, what exactly does the reservation cover, and do you need to do anything yourself.

Step 3: Keep a record, and look for your voice and face

Keep your contracts, your credits and the date of each job. They show what you agreed to, and what you did not.

Search now and then for your name, voice and face on video platforms, social networks and ad libraries. Fakes are easier to deal with the day they appear than a year later.

When you find one, save it before it disappears: the exact URL, screenshots, the account that posted it, and the date you saw it. Write the date down. The court action for an intrusion on your image or voice expires 4 years after you could first bring it (LO 1/1982 art. 9.5).

Step 4: Report it to the platform or the authority

In the EU, platforms that host content must let anyone report illegal content electronically (Digital Services Act, art. 16). A useful report gives the reasons, the exact URLs, your name and email, and a statement that you act in good faith. Also use the platform's own form for likeness, privacy or impersonation if it has one.

Send only solid reports. A platform may stop handling reports from senders who often send manifestly unfounded ones (DSA art. 23).

If the fake is sexual or violent, use the priority channel of the Spanish data protection agency (AEPD Canal prioritario), which asks for urgent removal, and think about a police complaint.

Step 5: Use the law that already exists, with a lawyer

Spanish Organic Law 1/1982, art. 7.6: using a person's name, voice or image for advertising, commercial or similar purposes without consent is an illegal intrusion. Once the intrusion is proven, harm is presumed (art. 9.3). A court can order it to stop, award damages and hand you the profit the other side made (art. 9.2).

If your recorded performance is reused or changed, the LPI is the other route. Art. 113.1 lets you object to changes that harm your prestige or reputation.

A lawyer can send a formal demand to the uploader or the advertiser. One open point: we found no Spanish court ruling on an AI voice or face clone (searched 13 October 2026), and it is not settled whether art. 7.6 covers a fully synthetic voice built without your recordings. Ask a lawyer who works on image and intellectual property rights.

What is coming

A bill to replace LO 1/1982 (file 121/000103) would have made any extremely realistic fake image or voice an illegal intrusion, not only in ads, and let a person forbid commercial AI use of their voice and image in their will. It lapsed when the Cortes were dissolved on 5 October 2026 for the 29 November election (Royal Decree 806/2026). So did the Labour Ministry's draft organic law on generative AI for artists. The next Government decides whether to bring them back. None of it is law.

Since 2 August 2026, the EU AI Act (art. 50(4)) requires whoever publishes a deepfake to disclose it clearly. Evidently artistic, satirical or fictional works only need a disclosure that does not spoil the work. If an ad uses a fake of you with no label, note that too.

AISGE asks for AI to be regulated inside the Intellectual Property Law, with transparency about training use, a collective reservation of rights, collective pay that cannot be waived, and a right to object to uses that damage an artist's reputation. Those are proposals, not law.