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Legal Situation: AI Images and Models

An overview for clients and models: the key facts at a glance. How does the legal framework for AI-generated images work in Switzerland and the DACH region?

1. Are AI-generated images legal?

Yes. AI-generated images are in principle legal in Switzerland and the EU. What matters is how they are produced and which rights are respected in the process. At Visari, every image is based either on fully synthetic models or on licensed likenesses of real persons — always with explicit contractual consent.

Switzerland: Personality rights (Art. 28 ZGB) protect the right to one's own image. A contractual consent allows the use of a person's likeness for defined purposes.

EU: The GDPR regulates the processing of biometric data. Explicit consent (Art. 9(2)(a)) is a prerequisite.

2. What does "Synthetic Origin" vs. "Human Origin" mean?

Synthetic Origin: The model is entirely computer-generated. It is not based on any real person. No third-party personality rights exist. Maximum flexibility in use.

Human Origin: The model is based on the licensed likeness of a real person. That person has signed a specific licence agreement defining the purposes for which the image may be used.

3. Labelling obligation: EU AI Act

The EU AI Act (in force since 2024, fully applicable from 2026) requires AI-generated images to be labelled as such. Visari transparently labels all generated images as "AI-generated", both in the metadata and upon delivery to clients.

Important for clients: When you use AI-generated images in your communication, a labelling obligation may apply depending on context. We are happy to advise you on the requirements for your specific use case.

4. Rights for clients

Usage rights

As a client, you receive clearly defined usage rights for the images you book. The scope depends on the agreed licence:

  • Standard licence: Use for the agreed campaign, defined channels and time periods
  • Exclusive licence: Time-limited or industry-exclusive usage rights. The model does not appear in any other campaign in your industry
  • Branded Model: Fully exclusive, unlimited use as a permanent brand asset

Licence documentation

You receive complete licence documentation that you can present to your legal department. This includes: scope of use, proof of model consent (for Human Origin), labelling notes and contract duration.

5. Rights for models

Consent and control

Every model signs a specific licence agreement under Swiss law. It clearly regulates:

  • The purposes for which the likeness may be used
  • Which uses are excluded (e.g. alcohol, tobacco, political content, erotic content)
  • That an expense compensation and revenue-share participation are agreed
  • That a right of withdrawal with a regulated transition period exists

Data protection

The photos submitted are used exclusively to train the AI model. After training is complete, the original photos are deleted. Processing takes place in accordance with the Swiss Data Protection Act (nFADP) and the EU GDPR.

No exclusive contract

Models do not enter into an exclusive contract. They remain free to work for other agencies or clients.

6. Swiss law as the basis

All Visari contracts are governed by Swiss law. Switzerland offers a strong legal framework for the protection of personality rights and data:

  • Art. 28 ZGB: Protection of personality — basis for the licensing of likenesses
  • nFADP (since 1.9.2023): New Swiss Data Protection Act — comparable to the GDPR
  • URG: Swiss Copyright Act — regulates rights to generated images

7. Frequently asked questions about the legal situation

Can we use AI-generated images in advertising?

Yes, provided that the usage rights are correctly licensed and the images are labelled as AI-generated. Visari provides the necessary documentation.

What happens if a model withdraws their consent?

The contract provides for a defined transition period. Ongoing campaigns can be completed as agreed. New bookings are stopped.

Are the images protected by copyright?

The legal situation regarding AI-generated images and copyright is being debated internationally. In Switzerland, the rule is: if a human significantly steers the creative process (prompt, selection, post-processing), copyright protection may exist. In any case, Visari recommends securing the images through the agreed licence.

How is Visari different from stock platforms?

Stock images are often not exclusive and do not offer a personalised visual language. Visari models can be booked exclusively, used consistently and tailored legally to your needs — including complete licence documentation.

Note: This page is for general information and does not constitute legal advice. For binding information on your specific use case, we recommend consulting a specialised legal adviser. Visari works with experienced lawyers and is happy to support you with legal questions related to our services. Contact: info@visari.ch

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All AI-generated images are based on licensed likenesses. © 2026 Visari, Zurich. Legally compliant under Swiss law.
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