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Japan Actors Union announces guidelines addressing unauthorised use of generative AI to replicate voice performances

The Japan Actors Union generative AI guidelines set out how actors’ voices and performances should be protected when AI tools are used. The recommendations focus on consent, compensation and preserving the artistic qualities of a performance, including when AI is used for voice replication or translation.

Image credit: Ritupon Baishya via Unsplash

What the Japan Actors Union generative AI guidelines recommend

The union advises obtaining an actor’s consent at every stage of generative AI use. This includes getting permission before a performance is used to train an AI model, not just before a generated voice or other output is released. For actors and production teams, documenting consent and agreeing on the intended uses in advance can help make those boundaries clear.

If AI reproduces an actor’s performance, the union says it should be treated as a new performance. That means actors involved should receive additional royalties or compensation. The recommendation recognises that a generated performance is a separate use of an actor’s work, rather than an automatic extension of the original recording.

Rules for replicating the voices of deceased actors

The guidelines also address voice replication after an actor’s death. Generative AI may reproduce a deceased actor’s voice only when the actor granted permission during their lifetime. Developers and AI companies must also obtain consent from the actor’s family and affiliated agency or company, and pay royalties.

These conditions make prior permission especially important. Families, agencies and production companies should establish who can authorize a proposed use and confirm that the necessary approvals and payments are in place before a voice is generated.

AI translation and artistic integrity

The union’s guidance covers generative AI translations of performances into other languages. Any translated version should retain the original performance’s “artistic integrity.” The guidance also says that an AI-generated translation cannot be used overseas without permission.

For studios planning multilingual releases, this means translation should be treated as a rights and creative decision as well as a technical process. Permission for one version or territory should not be assumed to cover other uses.

Push for broader voice-rights protections

The Japan Actors Union says it intends to promote the guidelines as industry-wide standards and encourage the government to introduce legislation protecting “voice rights.” The union’s position is that new technology should not come at the expense of human expression or respect for performers’ rights.

“Technological advancements will not stop, but the ‘living, breathing human expression’ and ‘respect for rights’ must always remain at its core,” the union said.

The issue is relevant to a games industry where research has found that more than half of Japanese developers use generative AI. Reported uses include visual assets, images, character art, story generation, in-game text and programming support.

In 2023, SAG-AFTRA members voted to authorize a strike against several major publishers, citing protection from AI-related risks and the need for job security. Following an 11-month strike, members approved the 2025 SAG-AFTRA Interactive Media Video Game Agreement. It included AI safeguards such as consent and disclosure requirements for digital replicas, as well as the ability for performers to suspend consent for generating new material during a strike.

UKIE has also announced a partnership with law firm Sheridans to provide an AI Compliance and Accreditation Service for UK studios seeking to use AI lawfully and responsibly.

Why the Japan Actors Union generative AI guidelines matter

The recommendations offer a practical framework for performers, agencies and developers: seek permission before using a performance, define the permitted use, account for compensation, and obtain separate approvals where translations or overseas distribution are involved. As AI tools become more common in entertainment production, clear agreements can help protect actors while giving studios a more responsible basis for using the technology.

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