AI-generated images of fictional people — not based on any real individual’s likeness — are generally permissible for marketing use, subject to your organization’s content guidelines. The restriction applies when the AI is generating content that uses, resembles, or is derived from a specific real person’s appearance or identity.
© 2005–2026 Xcelus LLC. All rights reserved. This content is for training and discussion only and is not legal advice; consult qualified counsel about your organization’s specific obligations.