Using real person’s face, likeness in AI media is illegal — NPC

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August 12, 2026 | 7:29am

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MANILA, Philippines — The National Privacy Commission reminded the public on Tuesday, August 11, that using artificial intelligence to generate photos and videos from a real person’s face or likeness and sharing or posting the result, are considered illegal under data privacy laws.

An individual’s face and likeness are personal information under Republic Act No. 10173 or the Data Privacy Act of 2012, according to the agency.

“Using AI tools to generate an image or video from a real person's face and likeness and posting or sharing the resulting image and/or video, are forms of processing of personal data, whatever the nature or purpose of the resulting media,” the data privacy authority said in a statement.

Among the illegal uses of AI-generated faces or likenesses are false depictions of a person’s actions or statements.

“AI-generated media that depicts a real person doing something the person never did, saying something the person never said, or being somewhere the person never was, is false information about that person,” NPC said.

Public officials, although subject to more publicity, are also considered data subjects and thus covered under the Data Privacy Act. Their family members, meanwhile, are considered private individuals fully covered by the law.

In the same statement, the agency explained that while a person’s consent is recognized, the processing of personal data must still have a lawful and legitimate purpose.

Without these lawful grounds, any act of generating and sharing AI-generated photos and videos bearing another person’s face is considered a violation.

The NPC reminded the public that anyone may file complaints before the agency if their face or personal data has been misused without their consent or a lawful purpose.

“A person whose likeness has been misused in an AI-generated media may demand its removal from the person or entity that posted or circulated it, and may file a complaint with the Commission,” NPC said.

Data Privacy Act violations constitute criminal, civil and administrative liabilities, such as imprisonment for one to three years and a fine of P500,000 to P2 million.

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