Gallery

Contacts

405 W. Greenlawn Ave Lansing, Michigan 48910

contact@techjacksolutions.com

+1-616-320-4064

Skip to content
Regulation Deep Dive

NO FAKES Act's Safe Harbor Fight: Who Wins, Who Loses, and What the Federal-State Landscape Means After June 11

6 min read Congress.gov Confirmed Strong
The Senate Judiciary Committee's June 11 markup vote on S.4591 isn't just a procedural milestone, it's the moment when competing visions of AI performer protection collide in a committee room. Entertainment industry groups have spent three years pushing for a federal right protecting voice and likeness from unauthorized AI replication; technology platforms have spent the same three years pushing back on the liability provisions that would make that right enforceable. This deep-dive maps who stands where, what the contested safe harbor provisions mean for compliance teams, and why the New York state law that took effect two days ago makes the federal outcome more consequential, not less.
Legislative markup attempts, 4th in 3 years

Key Takeaways

  • The June 11 markup vote, not a hearing, signals Grassley has assessed bipartisan support to advance S.4591 to the Senate floor; prior versions never reached this step
  • Safe harbor liability provisions for hosting platforms remain unresolved and are the primary variable in the markup outcome; their final form determines platform exposure
  • New York's AI Synthetic Performers Disclosure Law is already in force (effective June 6); compliance teams must build for both state requirements today and a potential federal floor on enactment
  • Bipartisan, bicameral structure, Blackburn/Coons in Senate, Salazar/Dean in House, with H.R.8915 as companion bill compresses reconciliation timeline if Senate bill passes
  • The federal-state preemption question is unresolved; NO FAKES Act would create a national floor but its interaction with existing state right-of-publicity and disclosure laws isn't settled

Timeline

2023-2025 Prior NO FAKES Act introductions (×3), all stalled before markup
2026-06-06 NY AI Synthetic Performers Disclosure Law takes effect
2026-06-08 S.4591 markup date announced by Grassley
2026-06-11 Senate Judiciary Committee markup vote, 10:15 AM, current position
TBD Senate floor vote (if committee approves)
TBD House-Senate reconciliation with H.R.8915 (if applicable)

NO FAKES Act, Stakeholder Positions

RIAA / Entertainment Industry
for
Formal RIAA endorsement; supports federal IP right closing AI deepfake gap
Sen. Blackburn (R-TN) / Sen. Coons (D-DE)
for
Lead Senate sponsors; bipartisan architecture deliberate
Rep. Salazar (R-FL) / Rep. Dean (D-PA)
for
House companion H.R.8915; parallel track to compress reconciliation
Technology platforms (hosting providers)
neutral
Safe harbor liability provisions under active negotiation; public position not confirmed

The NO FAKES Act has been introduced three times before. It died each time. The fourth introduction, S.4591, has done something its predecessors didn’t: it got a markup date.

That distinction matters. A markup vote isn’t a hearing. It’s a committee deciding it has counted the votes. When Sen. Chuck Grassley, who chairs the Senate Judiciary Committee, schedules an Executive Business Meeting rather than calling another round of testimony, that’s a signal, not a guarantee, but a signal, that leadership has assessed sufficient bipartisan support to advance. The scheduling of the June 11, 10:15 AM markup is the most concrete evidence in three years that this bill has momentum.

Where the NO FAKES Act Stands Today

S.4591 establishes a federal intellectual property right protecting individuals’ voices and visual likenesses against unauthorized AI replication. The scope is broad by design. It covers commercial use of AI-generated synthetic voice, AI-generated visual likeness, and deepfake video, regardless of whether the subject is a celebrity, a public figure, or a private person. The right is federal, which means it would create a national floor for enforcement rather than the current patchwork of state laws.

Sponsors span both parties and both chambers. On the Senate side, Sen. Marsha Blackburn (R-TN) and Sen. Chris Coons (D-DE) lead the bill. On the House side, Rep. María Salazar (R-FL) and Rep. Madeleine Dean (D-PA) have introduced companion bill H.R.8915. That bipartisan, bicameral structure is deliberate, and it’s why this iteration has moved further than earlier versions, according to legal analysis tracking the bill’s legislative history.

This is the fourth introduction in approximately three years. Previous versions stalled. None reached markup.

Who Supports the Bill and Why

The entertainment industry’s position is clear. The RIAA has formally endorsed S.4591, and the broader coalition behind the bill includes music industry organizations, film and television labor groups, and performing arts associations. Their argument is structural: AI voice cloning and synthetic likeness technology have developed faster than existing IP law can address. Right of publicity laws exist at the state level, but they vary enormously in scope, enforcement, and coverage. A federal standard would close that gap.

The bipartisan sponsorship structure reflects a genuine cross-party consensus on the underlying problem. Blackburn has been the most consistent congressional voice on AI deepfakes and synthetic media since the issue first emerged. Coons brings the Democratic side of the Senate Judiciary Committee. The addition of House sponsors Salazar and Dean signals that the House companion bill isn’t afterthought coordination, it’s a parallel track designed to compress the House-Senate reconciliation timeline if the Senate bill passes committee.

Individual rights advocates have also supported the bill’s framing. The core protection, your voice and likeness can’t be replicated commercially without your consent, is as applicable to a private person whose voice is scraped and cloned as it is to a recording artist.

Who Has Reservations and Why

Technology platforms haven’t publicly opposed the NO FAKES Act in its current form, but the safe harbor provisions are the fault line. How liability for hosting user-generated content gets structured will determine whether the bill is workable for intermediaries.

Who This Affects

AI product teams (voice/likeness applications)
Build consent frameworks now, New York's law is already in force, federal obligation follows if S.4591 advances
Technology platforms (UGC hosting)
Monitor markup outcome for safe harbor language, the final terms determine your liability exposure under a federal NO FAKES Act
Entertainment industry legal teams
Track the federal-state preemption question, NY law is operative; NO FAKES Act's interaction with state right-of-publicity laws isn't settled
Compliance officers
Map your synthetic content use cases against both NY current law and the anticipated federal standard; build for both simultaneously

The concern follows a familiar pattern from prior platform liability debates. If a platform hosts a synthetic voice clip that violates someone’s rights under the NO FAKES Act, what’s the platform’s exposure? Does the DMCA-style notice-and-takedown framework apply? Is there a knowledge standard, or is strict liability possible? These questions haven’t been definitively answered in the public version of the bill, and the negotiation going into the June 11 markup is focused on exactly this terrain.

The specific safe harbor terms aren’t publicly confirmed ahead of the markup, the Filter’s verification flagged this as contested but unresolved. What’s confirmed is that the issue remains live as of June 8. The markup may resolve it, or it may produce amendments that send the bill back for further negotiation on that specific point.

The New York State Law Parallel

This federal action doesn’t exist in a vacuum. New York’s AI Synthetic Performers Disclosure Law took effect on June 6, two days before this markup was announced. That law creates state-level disclosure requirements for AI-generated synthetic performers in entertainment productions.

The federal-state interaction is now live. New York’s law is already operative. A federal NO FAKES Act, if enacted, would establish a national standard that either preempts state laws like New York’s or coexists alongside them. That question, preemption or coexistence, isn’t settled in S.4591’s current public text.

For compliance teams operating across multiple states, this creates a sequencing problem. Do you build your synthetic voice and likeness compliance program around New York’s current requirements, around the anticipated federal standard, or around both simultaneously? The honest answer right now is both. New York’s law is in force today. The federal law is a committee vote away from advancing, and still multiple legislative steps from enactment.

The hub has been tracking the broader federal AI preemption debate. The NO FAKES Act fits into that landscape as a narrower, bipartisan carve-out, a federal floor for performer IP protection, rather than a broad preemption measure. That framing has helped it build support across the aisle while the broader preemption debate remains contested.

What Compliance Teams and Content Creators Should Watch After June 11

Three outcomes are possible on June 11. The committee approves S.4591 and sends it to the Senate floor, the scenario the bill’s sponsors are banking on. The committee approves S.4591 with amendments, most likely to the safe harbor provisions, which advances the bill but may require House-Senate reconciliation before enactment. Or the markup is postponed or the vote fails, returning the bill to the prior three iterations’ trajectory.

Each outcome has different compliance implications.

What to Watch

June 11 markup outcome, safe harbor language survives, is amended, or is removed3 days
Senate floor scheduling announcement if bill passes committee2-6 weeks post-markup
House H.R.8915 committee activity, parallel track can compress reconciliationQ3 2026
Additional state performer protection laws, NY is first; others may followOngoing

Analysis

The NO FAKES Act's fourth introduction follows the same structural logic as GDPR's eventual passage after years of stalled EU data protection reform: the underlying problem (unauthorized use of personal data / unauthorized AI replication of voice and likeness) didn't go away, and the technology causing it kept accelerating. What changed in both cases wasn't the policy argument, it was the political moment. For the NO FAKES Act, that moment may be June 11.

If the bill advances intact: Senate floor scheduling becomes the next milestone. Floor votes can move quickly or wait months depending on the legislative calendar. The House companion bill H.R.8915 creates a parallel track that could compress the timeline if the House moves independently.

If the bill advances with safe harbor amendments: The specific terms of those amendments will matter enormously for technology platforms. A narrow safe harbor that requires active knowledge of violations is workable. A broad strict liability provision is not.

If the markup stalls: The state-level patchwork, New York now, California’s existing right of publicity laws, and any additional state legislation that follows, becomes the operative compliance framework indefinitely.

The practical implication for today: if your organization uses AI voice cloning, synthetic likeness, or deepfake generation in any commercial context, you need a consent framework now. New York’s law already requires it for covered productions. A federal law would extend that obligation nationally. Building the consent infrastructure before the federal mandate arrives is cheaper than retrofitting it after.

The catch is the safe harbor language. Companies that host user-generated synthetic content, not just producers, may face obligations that aren’t fully defined until the markup concludes. Watch the markup outcome for whether safe harbor language survives intact, is narrowed, or is removed entirely. That’s the variable that determines platform liability exposure under a federal NO FAKES Act.

Four introductions in three years. The first three stalled. The fourth has a markup date, bipartisan sponsors in both chambers, and active entertainment industry endorsement from the RIAA. The June 11 vote won’t end this story, but it will determine whether federal AI performer protection finally has a path to the floor.

View Source
More Regulation intelligence
View all Regulation

Related Coverage

Stay ahead on Regulation

Get verified AI intelligence delivered daily. No hype, no speculation, just what matters.

Explore the AI News Hub