Law firm McDermott Will & Schulte has published guidance on New York's synthetic performer disclosure law, telling advertisers they now face specific disclosure obligations when campaigns feature AI-generated performers.

The advisory targets brands, agencies and their legal teams. It sets out what the New York law covers, when a disclosure duty kicks in, and what advertisers should do now to stay compliant.

What does the law actually regulate?

The subject is synthetic performers — artificially generated likenesses or voices used in advertising content. Under the New York measure, advertisers must disclose to audiences when a performer they see or hear is not a real person.

The guidance walks through the practical scope: which uses of synthetic talent fall inside the law, and which uses do not trigger disclosure.

Who needs to act?

The law firm frames its note squarely at advertisers. That means:

• Brands running campaigns in New York that use AI-generated performers
• Advertising agencies producing the creative
• Legal and compliance teams reviewing talent contracts and disclosures

The core message for operators: review your production pipeline now. If a campaign uses a synthetic performer and lacks the required disclosure, the advertiser carries the exposure.

Why now?

Synthetic talent has moved from novelty to production tool, with brands using AI-generated faces and voices to cut talent costs and speed up creative cycles. Regulators have followed. New York's disclosure law is part of that response, and the McDermott guidance signals that compliance questions are now landing on advertisers' desks, not just in legal reviews.

What should advertisers do next?

The guidance is a compliance checklist, not a policy argument. Advertisers should map where synthetic performers appear in current and planned campaigns, confirm the disclosure mechanics the law requires, and build those steps into creative approval workflows before launch.

For shops already using AI-generated talent, the cost of a disclosure step is minimal next to the cost of a campaign pulled for non-compliance.

Read the full advisory from McDermott Will & Schulte for the detail on thresholds, disclosure formats and enforcement exposure.