California SB 1111 digital replicas: avatar and face-swap checklist

SB 1111, listed in California's 30 September 2026 release as the "digital replicas" bill, updates civil and criminal law to protect likeness and to prevent false impersonation and AI deepfakes, including explicit content made without consent (press release, read 2026-10-02). If you generate avatar or face-swap video, the practical step is a written consent record per face, kept with the job.

What the release gives you

The release names SB 1111, its author and a one-line purpose. It does not state an effective date or the bill's definitions, so do not quote it as the law's text. Treat it as a signal about direction: likeness is being written into both civil and criminal law, which raises the cost of a missing consent record.

Where this touches Sume work

Sume's avatar videos start from a ready avatar identity and a script. Face swap (Beta) takes an avatar_handle and a public source video and applies that avatar's face to it. In both cases the face comes from an identity you created or were given, and the output is a replica of a likeness.

The face-swap docs list technical limits: a fetchable public HTTPS video, roughly 4-15 seconds with usable audio, and a required quality value. They do not describe a consent check, so assume Sume does not prove consent on your behalf.

Checklist before you render

• Whose face is it? Write down the person, the date, and what they agreed to, and store it with the avatar handle.
• Is the source video of a different real person? A face swap onto someone else's footage is the case impersonation language is aimed at.
• Is the use commercial? A paid ad also triggers disclosure rules, which are separate from likeness rules.
• Can the person withdraw consent? Keep the job ids so you can find and take down every output.
• Never use a celebrity or public figure's face without a signed agreement.

Honest limits

This is a checklist, not legal advice, and it rests on a press release summary. Sume stores jobs and artifacts under your workspace, which helps you find outputs later, but it does not enforce your consent process. Read the bill text or ask counsel before relying on it. If a collaborator supplies a face, ask for the same written record you would keep for your own.