Direct answer: An AI digital human or virtual anchor is not a video template. It combines portrait/voice rights, deep-synthesis labelling, advertising and endorsement rules, training data and a vendor contract. Before launch, settle who owns the face and voice, the scope and term of consent, whether the output is labelled, whether it counts as advertising, where data lives and who is liable—then discuss looks and lip-sync.

This guide is for marketing/brand, e-commerce/live commerce, customer service, legal/compliance, IT, procurement and vendors. It covers how to launch and accept AI digital humans, virtual anchors, digital twins and AI voice-overs. Information is current to 31 October 2026. It is public regulation, judicial interpretation and project method, not legal advice; portrait/voice consent, labelling, advertising review, platform rules and contractual liability are governed by the applicable rules, platform policies, signed authorisations and legal counsel.

Three rules first

Check the rights chain before model quality; a real person's face/voice needs explicit authorisation and separate consent; AI-generated/deep-synthesised content needs labelling; advertising, endorsement and live selling must be true and verifiable—never fake an expert, customer or medical result.

What kinds of AI digital human exist, and where do the risks differ?

Real-person clones, licensed digital twins, purely virtual personas and voice clones carry different risks. A real face/voice involves portrait and voice rights plus sensitive personal information; a virtual persona still involves training data, copyright and advertising.

"Digital human" is often sold as one product, but there are at least four types: a digital twin trained on a real person's photos/video; a virtual persona generated under a real person's authorisation; a fully fictional 3D/2D avatar; and an AI voice clone used only for audio. Real-person and voice clones involve portrait rights, voice interests and sensitive personal information; purely virtual personas involve copyright, trademarks, training data and advertising; live commerce adds platform rules and consumer protection. Classify first, then decide authorisation, labelling and contract.

TypeTypical useMain rights/risksConfirm first
Real-person digital twinFounder/expert/anchor presenting, customer servicePortrait/voice, personal information, advertising endorsementWritten authorisation/term/channels
Licensed virtual personaBrand virtual spokesperson, IP characterCopyright/trademark/scope of licenceIP ownership/use scope
Purely virtual personaBrand-built virtual anchor/service agentTraining data/copyright/advertisingMaterial sources/platform rules
AI voice cloneVoice-over, audio content, customer serviceVoice interests/sensitive personal informationSeparate consent from the voice owner
Digital-human live commerce24-hour streaming, product explanationAdvertising/consumer rights/platform rulesAd review/platform filing

The classification is editorial; specific rights, labelling, advertising and platform requirements depend on the use case, authorisation documents, platform rules and legal counsel.

How do you check the portrait/voice rights chain?

Portrait/voice authorisation must state who authorises, for what, on which channels, for how long, whether exclusive, whether training/adaptation is allowed, and how to withdraw/delete. A real face/voice is sensitive personal information and usually needs separate consent.

The most common failure is "we have the founder's/employee's/influencer's photos and recordings, so we can start training". Portrait rights and voice interests are not company assets just because the material is internal. The authorisation should state: the authorising person, the authorised entity, purpose/scenario, channels (website, Douyin, WeChat Channels, live stream, overseas), term, territory, exclusivity, whether AI training/adaptation/synthesis is allowed, whether sub-licensing is allowed, and deletion after withdrawal/termination. A real face/voice is sensitive personal information under the PIPL, requiring a specific purpose, strict necessity, strong protection and separate consent; employees, minors and deceased persons have additional rules.

Authorisation itemWhat to writeEvidenceCommon gap
Authorising partyThe person/guardian/rights holder; matches the materialID document/authorisationTreating employee photos as company assets
PurposeBrand promotion/service/live/training; no out-of-scope useAuthorisation, project brief"Global perpetual" is too vague
Channels/territoryWebsite/social/live/overseas/exhibitionsChannel listOnly "online"
Term/withdrawalStart/end, withdrawal method, deletion after terminationTerm, withdrawal recordNo term/irrevocable
AI training/adaptationWhether training, synthesis, adaptation and derivative works are allowedSpecific clausePhoto consent is not training consent
Sub-licensing/subcontractingWhether vendors/platforms/distributors may use itSubcontractor listVendor reuses the model
Minors/employeesGuardian consent/labour context/voluntarinessGuardian consent, employee communicationMandatory face scan/recording

The authorisation checklist is editorial; portrait/voice interests reference the Civil Code personality rights, and personal-information processing references the PIPL; specific consent depends on the facts and legal counsel.

How should deep-synthesis labelling work?

AI-generated/deep-synthesised digital-human video, audio, live streams and virtual scenes need explicit and implicit labels under the Labelling Measures and deep-synthesis rules. Do not remove, alter or conceal labels; platforms also have their own declaration rules.

Digital-human content is usually "AI-generated/synthesised" or "deep-synthesised" content. The Measures for Labelling AI-Generated Synthetic Content, effective 1 September 2025, require explicit labels (text/voice/graphics perceivable by users) on text, audio, images, video and virtual scenes, plus implicit labels in file metadata (generation attribute, service provider name/code, content ID). Users must declare when publishing, and no organisation or individual may maliciously delete, alter, forge or conceal labels. Digital-human live streams/short videos must also follow platform-specific AI declaration and labelling rules.

Content formLabelling requirement (editorial)EvidenceCommon failure
Digital-human short videoProminent notice at the opening/around playback; metadata labelScreenshot/metadataOnly "AI" in the description
Digital-human live streamProminent notice in the room/frame; platform declarationLive screenshot, platform recordPretending to be a real anchor
AI voice/audioVoice or rhythm notice at start/end/middleAudio sampleNo synthetic-voice label
Virtual sceneProminent notice at the opening; appropriate position during serviceScreenshot/recordingNo virtual-scene notice
Download/exportFile carries explicit + implicit labelsFile inspectionLabels lost after export
Re-sharingUser declaration; platform verification/noticePlatform rules/recordsRemoving/cropping labels

Labelling references the Measures for Labelling AI-Generated Synthetic Content and the Deep Synthesis Provisions; exact position/style/platform rules follow the original text and platform requirements.

What should you watch in digital-human advertising, endorsement and live selling?

Digital-human ads must be true and verifiable; do not fake experts, customers, medical results or data. A virtual persona can still count as advertising/endorsement. Live commerce must also follow platform and consumer-protection rules.

A digital human is not exempt from advertising law. If it recommends products, endorses a brand or sells live, the content must still be true and lawful: no false claims, no absolutes, no fabricated expert/patient/customer reviews, and no presenting AI-generated results/data as real cases. Using a real person's likeness for endorsement needs their authorisation and must be treated as an advertising endorser; a virtual persona must not imply unauthorised endorsement or make users think it is a real expert/customer. Platforms also impose filing, labelling, category and ad-review requirements on AI live streams/digital-human selling; confirm against the platform rules.

ScenarioWhat to doEvidenceRed flag
Brand endorsementReal-person authorisation/virtual IP; no implied unauthorised endorsementAuthorisation, contract"Founder recommends" without consent
Product explanationSpecs/price/results true; no absolutesProduct materials, review"Lowest/best in the world"
Expert/doctor imageNo fake expert/patient/results; medical ads follow rulesQualification, ad reviewAI posing as a doctor
Customer reviewsReal and verifiable; AI-generated reviews labelled/not misleadingReview recordsInvented customer reviews
Live commercePlatform filing/labels/category/consumer rightsPlatform recordsUnattended live stream without label
Data/resultsSource, sample and definition verifiable; no fake screenshotsReport/raw dataPhotoshopped/fake data

The advertising/endorsement checklist is editorial; ad review, endorsement and special-industry (medical, financial) requirements follow the Advertising Law, industry rules and platform policies.

How should the vendor contract and training data be handled?

The contract must cover material/training-data rights, portrait/voice authorisation, labelling, ad review, data location/deletion, subcontracting, infringement indemnity and exit. "The vendor guarantees compliance" is not enough.

Digital-human projects typically involve likeness/voice capture, model training, video generation, live-streaming tools, platform operations and cloud services. The contract should cover: sources and rights of material/training data, scope of portrait/voice authorisation, whether training and reuse are allowed, labelling of generated content, responsibility for ad review, data location/retention/deletion, subcontracting, infringement/complaint handling, indemnity, suspension/exit, and ownership of material/models. A vendor saying "we handle compliance" is not enough; put obligations, evidence and owners into the contract.

ClauseWhat to writeEvidenceRed flag
Material/training dataSource, rights, scope, whether training is allowedAuthorisation, data list"Found online"
Portrait/voicePerson/guardian authorisation, term, channels, withdrawalAuthorisationPhoto consent only, no training consent
LabellingExplicit/implicit labels, platform declaration, retained on exportSamples, platform recordsVendor removes watermark
Ad reviewWho reviews, who is liable, special-industry qualificationsReview records"Vendor says it is fine"
Data/deletionLocation, retention, deletion, access, subcontractingDPA, logsTraining data kept forever
Infringement/complaintsNotice, takedown, indemnity, defence, insurance (if applicable)Contract, SOPAll liability pushed to the client
Suspension/exitExport of material/model/account/generated content; deletionExit checklistVendor disappears on exit

The contract checklist is editorial and not a substitute for legal review; material/data/labelling/advertising/infringement/exit liability depends on the contract, platform and project.

Launch acceptance checklist

Accept eight items: rights chain, separate consent, labelling, ad review, training data, system security, contract, and monitoring/incident response. If any is missing, launch may become an infringement or false-advertising risk.

This checklist can be shared by brand, e-commerce/live commerce, customer service, legal, IT, procurement and vendors. The pass standard is not "does the digital human look real" but whether rights can be verified, labels are visible, ads are reviewed, data can be deleted and incidents can be handled.

CheckPass standardEvidenceIf failed
Rights chainPortrait/voice/IP/material authorisations complete; scope/term/channels clearAuthorisation, contractSuspend/obtain consent
Separate consentReal face/voice has separate consent; minors have guardian consentConsent recordObtain consent/suspend
LabellingExplicit + implicit labels; platform declaration; retained on exportSamples, metadataAdd labels/takedown
Ad reviewTrue/verifiable; special-industry qualifications; no absolutesReview recordsRevise/stop
Training dataLawful/authorised source; no out-of-scope use; deletableData list, DPAStop training/delete
System securityAccess/encryption/logs/watermark/tamper protectionConfig, logsRemediate/downgrade
ContractInfringement/complaint/indemnity/subcontracting/exit writtenContract, SOPAdd clauses/change vendor
Monitoring/incidentPublic-opinion/complaint/infringement notice/takedown/correction processMonitoring log, drillAdd process/training

The acceptance checklist is editorial; specific rights, labelling, advertising, data and contract requirements depend on regulations, platform rules, authorisation documents and legal counsel.

How should the 90 days be sequenced?

In 90 days: classify and check the rights chain, then authorisation/consent, labelling/platform, ad review, contract/data, testing/drills and launch. Do not train the model first and fix authorisation later.

The typical failure is "build the avatar first, obtain authorisation later". Start by classifying (real person/virtual/voice/live), checking the rights chain and platform rules, then decide whether to capture/train. Authorisation, consent, labelling, ad review and contract can run in parallel, but testing, training and incident drills must be complete before launch. For real people/employees/minors, communicate early and explain the purpose, scope and withdrawal.

PhaseActionsOutputsOwner
Weeks 0–2Classification, scenarios, platforms, material/training data, existing authorisation inventoryClassification table, risk listBrand/legal
Weeks 3–4Portrait/voice/IP authorisation and separate consent; minor/employee communicationAuthorisations, consent recordsLegal/HR
Weeks 5–6Labelling/platform declaration, ad review, data/contract/vendorLabel samples, contract, DPABrand/procurement
Weeks 7–8Generation/live testing; complaint/takedown/incident drills; trainingTest record, drillOperations/legal
Weeks 9–10Launch; monitor labels/ads/public opinion/data; handle exceptionsLaunch checklist, monitoringOperations/compliance
Weeks 11–12Review; authorisation expiry/withdrawal; model/material update/deletionReview, update planBrand/legal

The 90-day plan is editorial; authorisation, labelling, advertising, platform, contract and launch timing depend on the company, vendor and platform rules.

Who should read this, who should not, and what decision does it support?

It fits companies using digital humans for brand, live commerce, customer service or training. It does not fit teams without portrait/voice authorisation or ad review, or those wanting to impersonate real experts/customers.

Who should read: marketing/brand, e-commerce/live commerce, customer service, legal/compliance, IT, procurement and vendors; teams building a digital human/virtual anchor/digital twin/AI voice-over; anyone deciding "can we use a real face/voice, how to authorise it, how to label it, how to review ads, how to contract". Who should not: projects without clear authorisation/consent that want to impersonate real experts/customers/medical results; teams without ad review/platform rules/incident processes; projects expecting one checklist to replace legal advice. Decisions supported: digital-human classification, portrait/voice authorisation, labelling, advertising/endorsement, training data, vendor contracts, a 90-day plan and launch acceptance.

Lingyi Information is a website and enterprise AI project services company, not a law firm, advertising-review body or platform. This article does not replace portrait/voice authorisation, ad review, platform filing or legal advice. Project scope is confirmed case by case; no platform approval, ad approval, traffic, conversion or result is promised.

FAQ

Do we need authorisation to train a digital human on the founder's/employee's photos?

Yes. Portrait rights are personality rights; being an employee or founder does not make the likeness a free company asset. The authorisation should state purpose, channels, term, whether AI training/synthesis is allowed, and withdrawal/deletion. A real face/voice is also sensitive personal information and usually needs separate consent.

What should we watch with AI voice cloning?

Voice interests are protected by reference to portrait rights. Obtain explicit authorisation from the voice owner/guardian, covering scenarios, term, channels, training/synthesis and sub-licensing. Do not train on audio found online, customer call recordings or a departed employee's voice.

Must digital-human video/live streams be labelled?

When the content is AI-generated/synthesised or deep-synthesised, apply explicit and implicit labels under the Labelling Measures and deep-synthesis rules; platforms also have declaration/labelling rules. Do not delete, alter or conceal labels. Confirm exact position/style against the original text and platform requirements.

Can a digital human be an advertising endorser?

It depends on the scenario and authorisation. A real person's likeness used for endorsement needs their authorisation and must follow advertising/endorsement rules; a virtual persona must not imply unauthorised endorsement or fake an expert/customer/medical result. Special industries (medical, financial) also face industry review and platform rules.

Does digital-human live commerce need platform filing?

Platform rules differ and usually involve AI-live/digital-human labelling, category, ad review, consumer rights and account qualifications. Confirm against the target platform before launch; do not use "unattended live streaming" to evade labelling or review.

Is "the vendor guarantees compliance" enough?

No. The contract should cover material/training-data rights, portrait/voice authorisation, labelling, ad review, data location/deletion, subcontracting, infringement/complaint/indemnity, and suspension/exit. The company still needs to keep authorisation, consent, review and monitoring evidence.

Bottom line

For an enterprise AI digital human or virtual anchor, check the rights chain first: a real face/voice needs authorisation and separate consent, AI-generated/deep-synthesised content needs labels, advertising/endorsement/live selling must be true and verifiable, and training data/vendor contracts must be explicit. Accept with a checklist before launch; looking real is not the first question—lawful use and incident handling are.

Method and limits

This article is public regulation, judicial interpretation and project method, not a compliance certification or legal advice for any company, digital human, platform, advertisement or contract. It uses no unpublished client material, authorisation or contract. The classification, tables and 90-day plan are editorial suggestions; portrait/voice authorisation, labelling, ad review, data and contractual liability depend on the regulations, platform rules, authorisation documents and legal counsel.

Sources

Information is current to 31 October 2026; each official/primary page governs its own scope, version and clauses.

  1. Measures for Labelling AI-Generated Synthetic Content (effective 1 September 2025): cac.gov.cn. Explicit/implicit labels, download/export, user declaration and the prohibition on deleting/altering labels.
  2. Provisions on the Administration of Deep Synthesis of Internet Information Services (effective 10 January 2023): cac.gov.cn. Notice/separate consent for face/voice editing, security assessment, labelling and filing.
  3. Personal Information Protection Law of the PRC: npc.gov.cn. Separate consent, impact assessment and minimisation for sensitive personal information such as faces and voices.
  4. Civil Code of the PRC, Book on Personality Rights: npc.gov.cn. Portrait rights, voice interests protected by reference, and the prohibition on making/using/publishing without consent.
  5. Advertising Law of the PRC (2021 amendment): SAMR. Advertising must be true and verifiable; no false/absolute claims or fabricated endorsement/proof.
About the author

Lingyi Information Official (delivery team) works on corporate websites, brand and brochure design, smart manufacturing and AI projects, including requirements, proposals and acceptance coordination. This article is public research and project-method guidance, not legal advice on portrait/voice, personal information, advertising or contracts; each project is governed by the regulations, platform rules, authorisation documents, contract and legal counsel.

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