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AI & endorsements · TRUST & SAFETY

AI in sponsored content: labels, virtual influencers and likeness

Short answer

If sponsored content uses AI to show realistic-looking people, events or voices, add an AI label and keep the paid-partnership label on. TikTok, Instagram and YouTube require disclosure of realistic AI content, and TikTok bans AI that makes public figures appear to endorse products. Indonesia has no AI-labelling law yet; the presidential regulations on AI were still awaiting the President’s signature in October 2026. For a talent’s face and voice, agree in writing whether the brand may use AI, for what, for how long and for what fee.

CariTalent editorial team · Sources checked · For: Creators, talent, brands and agencies · General guidance, not legal advice

When must AI content be labelled on TikTok, Instagram and YouTube?

  • TikTok: AI or heavily edited content showing realistic people or events must be labelled, for example swapped faces or AI voices mimicking real people. Use the AI-generated label or a clear caption. Even with a label, showing a public figure endorsing a product they never endorsed is banned.
  • Instagram and Facebook: Meta requires a label before sharing photorealistic video or realistic-sounding audio that was digitally made or altered, including AI voice-overs on reels. Use the Add AI label toggle.
  • YouTube: disclose realistic content that makes a real person appear to say or do something they did not, alters footage of real events, or shows realistic scenes that never happened. The setting is called AI use in YouTube Studio.
  • None of the three requires a label for minor edits such as beauty filters or AI-assisted scripts, and each may add a label automatically when it detects AI signals.

How should AI be used in paid content?

An AI label does not replace an ad label. Also switch on TikTok’s commercial content disclosure, Instagram’s paid-partnership label or YouTube’s paid-promotion disclosure. Indonesia’s advertising code requires ads on personal social media to be clearly disclosed, testimonials to reflect real experience, and no one to appear in an ad without their consent.

  • Never use AI to create testimonials of experiences that did not happen.
  • Never make a talent appear to say claims they did not approve.
  • Keep the original material and note which parts AI created or changed.

What rules apply to virtual influencers?

A virtual influencer is a persona made with AI or computer graphics. Instagram offers an AI-generated profile label for accounts that regularly feature an AI-generated person. Because Indonesia’s advertising code requires testimonials to reflect real experience, a virtual influencer should not give testimonials as if it had used a product. Say in the bio who runs it, and disclose every paid partnership as a human creator would.

Who controls a talent’s face and voice?

  • Copyright Law 28/2014 Article 12: commercial use of a portrait for advertising needs written consent from the person portrayed or their heirs.
  • Personal Data Protection Law 27/2022 treats biometric data such as facial images as specific personal data and bans the unlawful use of other people’s personal data. It does not name voice explicitly.
  • Indonesia’s advertising code bans ads that show or involve a person without prior consent.
  • TikTok defines likeness as face, body, voice and gestures, and YouTube says labelling content as synthetic does not permit using someone’s likeness without permission.
Important

How these rules apply to AI recreations has barely been tested in Indonesian courts. A written contract is therefore the best protection for talent and brands.

What goes in an AI and likeness contract clause?

CariTalent’s endorsement, UGC and event-talent templates now include an AI and likeness clause that defaults to “not permitted”.

  1. Step 1: Start from “not permitted”

    Without specific written consent, the brand may not use AI to alter, extend or recreate the talent’s face or voice, or use the material to train AI models.

  2. Step 2: Be specific if permitted

    State the use (for example dubbing into another language), media, territory, period and extra fee.

  3. Step 3: Approval of outputs

    The talent approves every AI output before it runs, with no new statements they did not approve.

  4. Step 4: Labels and deletion

    AI outputs are labelled under platform rules, and face or voice models are deleted when the term ends.

Does Indonesia have AI rules yet?

  • Ministerial Circular 9/2023 on AI ethics is addressed to AI developers and electronic system operators, not to creators.
  • Two draft presidential regulations, on an AI roadmap and AI ethics, were reported as still awaiting the President’s signature in September and October 2026.
  • Komdigi has said it plans to require platforms to label or watermark AI content through a ministerial regulation after the presidential regulation is issued; that rule has not been issued.

Frequently asked questions

Must AI-edited sponsored content be labelled?

Yes, if it shows realistic-looking people, events or voices that were made or altered, such as face swaps or AI voices. Minor edits like beauty filters do not need a label under TikTok, Meta and YouTube rules.

Can a brand recreate my voice or face with AI?

Only with your written consent stating the use, media, term and fee. Without that, do not allow it, and make sure your material is not used to train AI models.

Can virtual influencers take endorsements?

Yes, with an AI profile label, paid-partnership disclosure and no testimonials as if it had used the product.

Does Indonesia have an AI law yet?

Not yet. As of October 2026 there is Ministerial Circular 9/2023 on AI ethics, while two draft AI presidential regulations await the President’s signature.

Does an AI label replace an ad label?

No. Paid content still needs a paid-partnership disclosure, and realistic AI content also needs an AI label.

Official sources we checked

Rules and platform policies change. Check these sources before deciding, and ask a lawyer to review high-value deals. We review platform AI policies quarterly and whenever Indonesia issues its AI presidential or ministerial regulations.

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