New York’s AI Disclosure Law Takes Effect June 9. If Your Amazon Listings Feature AI-Generated Models, You Need to Act Now.

13 May 2026

New York’s AI Disclosure Law Takes Effect June 9. If Your Amazon Listings Feature AI-Generated Models, You Need to Act Now.

AI-generated lifestyle models have become standard practice for Amazon sellers. The quality has improved dramatically, the cost is a fraction of traditional photography, and the turnaround time is measured in hours rather than weeks. Most brands have adopted them without a second thought.

That calculus just changed — at least for content reaching New York audiences.

What the Law Actually Says

On December 11, 2025, New York Governor Kathy Hochul signed S.8420-A/A.8887-B into law — described by the Governor’s office as first-in-the-nation legislation to protect consumers and boost AI transparency in advertising.

The law amends New York General Business Law § 396-b and takes effect June 9, 2026. It requires all persons producing or creating advertisements that include AI-generated synthetic performers to conspicuously disclose that fact.

The definition matters here. A “synthetic performer” is any humanlike figure generated or substantially altered by AI software to appear as a person performing in a commercial advertisement. This is not limited to obviously synthetic CGI characters. It covers AI-generated lifestyle models that look entirely human — the kind increasingly used in Amazon product imagery, A+ content, and brand store visuals. Amazon

The law applies to any commercial advertising produced or created for distribution in New York, covering brands, agencies, franchises, and local production partners. It even extends to influencer marketing campaigns and regional content. There are exclusions for audio-only content, AI used solely for translation, and marketing for expressive works like films where the synthetic performer regularly appears in the underlying work — but standard product advertising does not qualify for those exclusions.

Why Amazon Sellers Are Directly in Scope

The geographic reach of this law is the critical detail for any brand selling on Amazon.

This legislation applies to any usage of synthetic performers in advertisements distributed to New York audiences, regardless of whether the advertiser is located outside of the state. Amazon listings are accessible to every shopper in New York. That makes them advertisements distributed to a New York audience, which puts them squarely within the scope of the requirement.

There is also a federal dimension worth tracking. On December 11, 2025 — the same day Governor Hochul signed the bill — the White House issued a sweeping Executive Order seeking to pause all state-level AI regulation in favor of a yet-to-be-determined federal standard. The Executive Order signals the need for a single national AI law that would preempt state AI laws. Though some states may face aggressive federal challenges, the Executive Order itself is likely to be challenged in court. In the face of that uncertainty, the practical guidance is clear: prepare for compliance with the New York law and monitor federal developments. June 9 is not moving.

What Non-Compliance Actually Costs

Failure to comply with the disclosure requirement may result in civil penalties of $1,000 for a first violation and $5,000 per subsequent violation. The statute does not provide a private cause of action — enforcement comes through civil penalties rather than individual lawsuits — but the escalating structure means repeated violations compound quickly.

For brands running multiple ASINs with AI-generated lifestyle imagery across hundreds of assets, the exposure is not trivial. A systematic audit of existing content is worth the time.

What “Conspicuous Disclosure” Means in Practice

The law requires the disclosure to be conspicuous — meaning it has to be visible and legible, not buried in fine print. For Amazon content, this translates to a small text disclaimer added directly to the image or included clearly in the listing.

Practical options that work for Amazon product imagery:

“This advertisement features AI-generated models.” — clean, neutral, directly compliant.

“Imagery includes AI-generated models.” — minimal, easy to incorporate into existing layouts.

“AI-generated models. Human-obsessed creative.” — brand-forward, for sellers who want to lean into the transparency rather than just meet the minimum requirement.

The implementation is straightforward. Open the asset in any design tool, add the disclaimer as a visible text layer, and re-upload to Seller Central. For most assets, this is a 10-minute task per image once the template is set.

The more time-consuming part is the audit — identifying which existing assets in your catalog feature AI-generated human figures, and prioritizing which to update before June 9. Start with your highest-traffic ASINs and main listing images. A+ content and brand store imagery should follow.

The Broader Context

New York is the first state to pass this specific requirement, but it reflects a regulatory direction that is accelerating nationally. New York’s synthetic performer law builds upon the efforts of lawmakers across the US seeking to regulate AI-powered technologies and follows the enactment of numerous state laws governing AI chatbots during 2025. Other states are watching. A federal standard may eventually replace or supplement state laws — but that timeline is uncertain, and June 9 is not.

The law was strongly supported by SAG-AFTRA, the professional performers’ union, which has been adopting its own requirements to protect working performers from being displaced by AI-generated synthetic performers or unfairly replicated using generative AI technologies. The compliance pressure here is not just regulatory — it reflects a broader shift in how AI-generated content in advertising is being treated by regulators, unions, and increasingly, consumers.

For brands that have built AI-generated lifestyle imagery into their content workflow, this is not a reason to change the workflow. It is a reason to add one step: the disclosure. The cost is minimal. The alternative is a $5,000 per-violation exposure on every piece of non-compliant content distributed to New York audiences.

June 9 is four weeks away. The audit should already be underway.

Important note: This post shares publicly available information about a new law and practical implementation considerations. It does not constitute legal advice. Consult your legal counsel to determine what compliance looks like for your specific situation.

If you want to stay updated on Amazon changes, subscribe to our blog.

If you need support with PPC, DSP, AMC, analytics, or a long-term growth strategy, contact the ANavigator team at info@anavigator.co

🚀 Book a call to get a FREE AUDIT by the link below: 🚀
⬇️ ⬇️ ⬇️
Book a call – FREE AUDIT

 

Follow my Weekly Newsletter on LinkedIn:
 / amazon-digest-for-brands-7232361008185372672  
Follow me on LinkedIn:
 / ookovalov 
Follow ANavigator on social media:
 / anavigator  
 /@anavigator_official
 / anavigator7  
 / @anavigators  

 

LinkedIn page to contact us:

 

Author: Oleksandr Kovalov
Role: Founder & CEO @ ANavigator
— The ANavigator Team

our activity

News and podcasts

LATEST UPDATES

Amazon Just Removed Custom Return Instructions for FBM Sellers
Blog
August 20, 2026
Amazon Just Removed Custom Return Instructions for FBM Sellers
Starting August 2026, a field that seller-fulfilled brands have quietly relied on for years disappeared from Seller Central. The option to add custom return instructions in Return Settings and the Manage Seller-Fulfilled Returns screen is gone, confirmed by Amazon moderator Billy_Amazon in the Seller Central forums when sellers began reporting the change around August 13. Amazon's notice was a single sentence: "Starting August 2026, the option to add return instructions in your return settings will no longer be available." No replacement was announced. No equivalent field was introduced. For brands selling bulky, expensive, fragile, or condition-sensitive products through FBM, the implications are worth thinking through carefully, particularly in the context of five other FBM return changes that have already taken effect in 2026. What Sellers Actually Lost The custom return instructions field allowed FBM sellers to communicate specific requirements directly to buyers when a return was authorized. Common uses included telling customers to return items unused, include original packaging, use specific packaging materials, or understand that return shipping was their responsibility when the item was not defective. For products where condition on return directly affects resale value- outdoor equipment, electronics accessories, custom items, fragile goods, anything with hygiene or safety considerations- that field was doing real operational work. It set expectations before the package was shipped back, which reduced the frequency of returns arriving damaged, used, incomplete, or improperly packaged. Without it, buyers now receive a return label with Amazon's standard messaging. The seller has no dedicated channel to communicate product-specific return requirements at the moment of return authorization. Amazon's stated alternative is Buyer-Seller Messaging; FBM sellers can still reach buyers through the messaging system to communicate return requirements. That is technically true, but it is a manual, reactive step rather than a systematic one. It requires the seller to initiate a message after every return authorization, and it is subject to Amazon's messaging policies, which restrict commercial communication. The Broader FBM Return Picture in 2026 The removal of custom return instructions is one piece of a larger pattern of FBM return policy changes that have accumulated throughout 2026. Taken together, they represent a significant tightening of how seller-fulfilled returns work, and a consistent shift toward Amazon controlling more of the return experience while sellers absorb more of the cost. Effective February 8, 2026, all FBM sellers must use Amazon prepaid return labels for every order, regardless of item value. The previous high-value exemption, which allowed sellers of electronics, jewelry, cameras, and other expensive items to opt out of prepaid labels, was eliminated entirely. Sellers of high-ticket items now absorb prepaid return shipping costs on every return. Effective January 26, 2026, the FBM refund processing window was extended from two business days to four calendar days. If a seller does not process a refund within four calendar days of receiving a returned item, Amazon may issue an automatic refund, and in most cases, the seller loses eligibility for SAFE-T claim reimbursement. The four-day window sounds generous but requires tight operational discipline. Returns that arrive on Friday need a decision by Monday. Returns that arrive around holidays compress the inspection timeline further. Sellers previously had two business days, which excluded weekends. The new four calendar-day window sounds longer but is operationally shorter in practice for sellers without weekend fulfillment operations. What FBM Sellers Should Do Now The absence of a custom instructions field does not mean you have no options. It means the options require more proactive effort. The most effective replacement for custom return instructions is proactive messaging. When you authorize a return, immediately send a Buyer-Seller message that covers your key return requirements: unused condition, original packaging, return shipping responsibility if applicable. This does not happen automatically, so it needs to be built into your return authorization workflow as a standard step, not an occasional practice. For products where specific handling is genuinely important- fragile items, products with hygiene implications, items where incomplete packaging significantly affects resale value- review whether your product detail page, packaging inserts, and any post-purchase communications address return expectations proactively. Reducing the information gap before a return is initiated is more reliable than bridging it at the point of authorization. On the SAFE-T claim side, the four-day inspection window is now the critical deadline. A seller generally has four days after receiving the returned product to inspect it and submit a SAFE-T claim. Eligible claims may cover the return label cost plus up to 50% of the item's price, depending on circumstances and product category. If returned inventory arrives damaged, used, or incomplete, document the condition immediately upon receipt and submit the SAFE-T claim within the window, not after. For brands with high-value SKUs where the combination of mandatory prepaid labels, four-day refund windows, and now removed return instructions creates compounding risk, the economics of FBA versus FBM are worth revisiting by ASIN. FBA fees are higher, but Amazon takes on the return risk and associated costs for FBA inventory. For high-value items where damage or fraud is a real concern, those extra fees may now be cheaper than the combined cost of prepaid labels, damaged returns, and missed SAFE-T claims. The Broader Pattern 2026 has been the most active year for FBM return policy changes in recent memory. Mandatory prepaid labels, a revised refund window, high-value exemption removal, and now the elimination of custom return instructions have all landed within eight months. Each change individually is manageable. Together, they represent a consistent shift: Amazon is standardizing the return experience for buyers at the cost of seller control and flexibility. For brands running significant FBM volume, the practical response is not to fight the direction; it is to rebuild operational workflows around the current reality, document returns thoroughly, use SAFE-T claims consistently, and evaluate whether FBM remains the right fulfillment model for each SKU in your catalog. The custom return instructions field is gone. The work it was doing still needs to happen; it just requires more deliberate effort than it did before August 2026. If you want to stay updated on Amazon changes, subscribe to our blog. If you need support with PPC, DSP, AMC, analytics, or a long-term growth strategy, contact the ANavigator team at info@anavigator.co  Book a call to get a FREE AUDIT using the link below:     Book a call – FREE AUDIT   Follow my Weekly Newsletter on LinkedIn:  / amazon-digest-for-brands-7232361008185372672   Follow me on LinkedIn:  / ookovalov  Follow ANavigator on social media:  / anavigator    /@anavigator_official  / anavigator7    / @anavigators     LinkedIn page to contact us:   Author: Oleksandr Kovalov Role: Founder & CEO @ ANavigator — The ANavigator Team
Learn more
Blog
August 18, 2026
Since September 2025, Amazon DSP advertisers have had access to Netflix's ad inventory. What changed on August 4, 2026, is practical: Amazon published the full technical documentation for how to actually set up a Netflix campaign through Amazon DSP, including deal types, vendor requirements, frequency capping, audience limitations, and reach reporting. The integration is no longer in early access. It is a live, documented advertising channel. For brands already running Amazon DSP, this is worth understanding in detail before adding it to a media plan. Why This Integration Exists Netflix reaches a unique and attentive audience - 44% of members who see an ad on Netflix never saw it on broadcast TV or other streamers. Campaigns on Netflix drive almost 2x the TV norm on long-term brand building and 23% above benchmarks on purchase intent compared to competitors. Amazon's interest in the partnership is straightforward. Amazon DSP's authenticated identity graph, built from purchase behavior, browsing signals, and retail data, can now be applied to Netflix's premium streaming environment. A retail brand that previously could use Amazon's purchase data only to target audiences on Amazon-owned properties can now extend those same audience definitions to Netflix inventory. Amazon's purchase signals reach Netflix's living room. For brands, this collapses a step that previously required separate negotiations, separate tech stacks, and separate measurement. Netflix inventory is now accessible through the same DSP interface, the same deal workflow, and the same reporting layer you use for Prime Video and other streaming placements. How Netflix Campaigns Work in Amazon DSP Netflix supply is available for private auction and programmatic guaranteed deals only, it is not available through open auction. Before creating a campaign, you need a Netflix deal with the correct configuration. Existing deals are not compatible with Amazon audience-enabled campaigns and will not work. There are two ways to secure a deal. You can work with Netflix or your Amazon Ads representative directly, in which case the deal appears automatically in your Amazon DSP manager account via API once it is ready. Or you can submit a deal proposal to Netflix directly inside Amazon DSP through the deal proposal workflow. Once a deal is in place, the campaign setup follows the standard Amazon DSP structure: campaign, ad groups, and ads. Activation is straightforward: enable the ad groups and campaign via the toggle in the Campaigns interface. Vendor requirements are strict. Netflix maintains firm third-party vendor requirements for all ad serving and measurement. Supported ad serving vendors are Google Campaign Manager 360 and Innovid. Supported measurement and verification vendors are DoubleVerify and Integral Ad Science. All other third-party vendors are not supported. If you are currently using a different vendor for your DSP campaigns, you will need to switch to one of the approved options or use Amazon DSP-hosted ad options before running on Netflix inventory. What Amazon Audiences Can and Cannot Do on Netflix Starting Q2 2026 in the US, advertisers can apply Amazon Audiences to Netflix campaigns, audience segments built from Amazon's purchase and behavioral data, applied to Netflix's streaming environment. That is the meaningful capability at the center of this integration. Your Amazon customer cohorts, category buyers, high-LTV segments, competitor brand shoppers, can now be used to target audiences on Netflix. The limitations are specific and worth knowing before building a campaign: Amazon audiences are available on private marketplace run-of-network deals only. They are not available on programmatic guaranteed deals. Do not layer third-party audiences, genre detargeting, or Netflix-side targeting on Amazon audience-enabled deals - this will stop delivery. Similar audiences and durable audiences are not available on Netflix inventory. Ad Exposure remarketing is not available. Audience-level reporting is not available. Brand safety settings through Amazon DSP do not apply to Netflix inventory; contact Netflix directly for brand safety options. Frequency caps are fully enforced for private auction and preferred deals. For programmatic guaranteed deals, impressions count toward caps but cannot be suppressed on the Netflix line item. What Is Actually Measurable De-duplicated reach and frequency metrics are now available for Netflix ad group lines and populate automatically, no setup, no opt-in, no additional cost. These metrics are available across all 11 Netflix ad-supported locales. Netflix and Spotify are now direct integrations available through Amazon DSP, with reach and frequency metrics that feed into cross-publisher measurement. That matters for brands running streaming TV alongside Netflix; you can measure unduplicated reach across Prime Video, Netflix, and other inventory sources from the same platform, without reconciling separate reports. The measurement piece is what has historically made streaming TV difficult to justify in a performance-oriented media plan. De-duplicated reach and frequency data, combined with Amazon's purchase attribution from the same DSP, changes that calculus meaningfully. What Brands Should Be Thinking About Before Running Netflix Campaigns Netflix inventory is premium, which means it is expensive relative to other streaming placements, and the minimum deal thresholds reflect that. This is not a format to test with a small budget expecting performance metrics comparable to Sponsored Products. The right frame for Netflix through Amazon DSP is brand building with measurable audience reach, not direct-response conversion. The brands for whom this makes sense have a few things in common. They are already running Amazon DSP with meaningful budget; Netflix is an addition to a working DSP strategy, not a standalone channel. They have a product or brand story that benefits from a lean-back, high-attention streaming context. And they have creative that is production-quality for the streaming environment, not repurposed Sponsored Brands video. A recent Dove campaign spanning consumer products and custom creative on Netflix saw an almost 60% increase in new shoppers for products. That result reflects both the reach quality of Netflix's audience and the creative investment Dove made for the placement. The format rewards brands that treat it like a premium channel, not a cheaper extension of search advertising. If you are running Amazon DSP and have not yet looked at Netflix as an inventory source, the August 2026 documentation update is a useful moment to evaluate it. The technical setup is now clearly documented, the audience integration is live, and the measurement tools are in place. Whether the economics make sense depends on your category, your brand objectives, and your existing DSP performance, but the access barrier that existed before the Amazon partnership is gone. If you want to stay updated on Amazon changes, subscribe to our blog. If you need support with PPC, DSP, AMC, analytics, or a long-term growth strategy, contact the ANavigator team at info@anavigator.co  Book a call to get a FREE AUDIT using the link below:     Book a call – FREE AUDIT   Follow my Weekly Newsletter on LinkedIn:  / amazon-digest-for-brands-7232361008185372672   Follow me on LinkedIn:  / ookovalov  Follow ANavigator on social media:  / anavigator    /@anavigator_official  / anavigator7    / @anavigators     LinkedIn page to contact us:   Author: Oleksandr Kovalov Role: Founder & CEO @ ANavigator — The ANavigator Team
Learn more