ElevenLabs · ElevenLabs Usage Policy · View original document ↗

Impersonation of Real Individuals

Medium severity Medium confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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What it is

You cannot use ElevenLabs to create a voice that impersonates a real person in a way that could deceive people or harm that person's reputation.

This analysis describes what ElevenLabs's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Impersonation using AI voice technology creates direct fraud, defamation, and reputational harm risks; this provision establishes ElevenLabs' policy position and sets user liability for such uses.

Interpretive note: The policy does not address satire or parody carve-outs, leaving the boundary between prohibited impersonation and permissible expressive use ambiguous.

Consumer impact (what this means for users)

Users who create synthetic audio that impersonates identifiable real individuals in a deceptive or harmful way are in violation of this provision and face account termination, as well as potential civil liability for defamation, fraud, or identity misrepresentation.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
You may not use the Services to impersonate any real person, including public figures, in a manner that is likely to deceive others or cause harm to that individual's reputation or safety.

— Excerpt from ElevenLabs's ElevenLabs Usage Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision engages common law defamation and right of publicity doctrines, state identity fraud and impersonation statutes, the FTC Act's prohibition on deceptive practices, and the EU AI Act's transparency obligations for AI-generated content that could be mistaken for authentic speech by real individuals. Platform liability frameworks under Section 230 (US) and the DSA (EU) are also relevant to how ElevenLabs' own exposure is framed. (2) GOVERNANCE EXPOSURE: Medium to High. The prohibition on harmful impersonation is broadly consistent with legal requirements, but the policy's use of 'likely to deceive' and 'cause harm' introduces an interpretive standard that may be contested in enforcement scenarios, particularly where satirical or parodic content is involved. (3) JURISDICTION FLAGS: Right of publicity claims are strongest in California and New York. Defamation exposure varies significantly by jurisdiction. EU users benefit from stronger personal data and dignity protections. The policy does not carve out satire or parody, which may create tension with free speech principles in US jurisdictions. (4) CONTRACT AND VENDOR IMPLICATIONS: B2B customers should assess whether their products permit user-generated content involving impersonation and implement moderation controls accordingly. The AUP places liability on the end user, but platform-level due diligence may be expected by regulators in some jurisdictions. (5) COMPLIANCE CONSIDERATIONS: Legal teams should evaluate whether the policy's lack of a satire or parody carve-out creates operational friction for legitimate creative use cases, and may wish to seek clarification from ElevenLabs on permissible expressive uses of voice synthesis involving public figures.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    FTC has authority over deceptive commercial practices, including impersonation used in fraud or consumer deception schemes.
    File a complaint →
  • State AG
    State attorneys general have authority under state identity fraud, right of publicity, and consumer protection statutes.
    File a complaint →

Provision details

Document information
Document
ElevenLabs Usage Policy
Entity
ElevenLabs
Document last updated
May 11, 2026
Tracking information
First tracked
May 11, 2026
Last verified
May 11, 2026
Record ID
CA-P-010711
Document ID
CA-D-00779
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
3b04c061ee875cc733cfece1b436238b97a43b0e5ec22aaacc3176c33d57981a
Analysis generated
May 11, 2026 13:18 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: ElevenLabs
Document: ElevenLabs Usage Policy
Record ID: CA-P-010711
Captured: 2026-05-11 13:18:12 UTC
SHA-256: 3b04c061ee875cc7…
URL: https://conductatlas.com/platform/elevenlabs/elevenlabs-usage-policy/impersonation-of-real-individuals/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does ElevenLabs's Impersonation of Real Individuals clause do?

Impersonation using AI voice technology creates direct fraud, defamation, and reputational harm risks; this provision establishes ElevenLabs' policy position and sets user liability for such uses.

How does this clause affect you?

Users who create synthetic audio that impersonates identifiable real individuals in a deceptive or harmful way are in violation of this provision and face account termination, as well as potential civil liability for defamation, fraud, or identity misrepresentation.

Is ConductAtlas affiliated with ElevenLabs?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by ElevenLabs.