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.

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Author: Oleksandr Kovalov
Role: Founder & CEO @ ANavigator

— The ANavigator Team