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User verification for AI services and consent to a digital likeness

Before you make an avatar, “animate” a photo or clone a voice, make sure the materials were uploaded by their owner. NeuroVision checks the document and live presence and matches the face against the materials for the likeness. For API access — a check of the company and its representative; for data labellers — one person per account.

Result of the likeness owner check before creating a digital avatar: document, Liveness, deepfake signs and face matching
195+ countries and territories — documents without manual entry
16 000+ document types
from 29 ₽ per "Document + liveness" session
from 16 ₽ per “Document” session
Document Liveness Deepfake signs Face matching Company by tax number Self-employed

Consent of the likeness owner is confirmed by the owner · 152‑FZ

Face, voice and personal data: the rules on which consent to a digital likeness rests

There is no law that obliges an AI service to verify its users — even the AI law adopted in summer 2026 does not require it. But a person's face and voice are protected by the Civil Code and the personal data law, and the service will answer for someone else's likeness in a model.

  • Image and voice

    Civil Code of the Russian Federation, Art. 152.1; draft law No. 718834‑8 (Art. 152.3 of the Civil Code) — not adopted.

    Consent to the voice

    Image

    • A citizen's image, including photos and videos, may be made public and used only with their consent
    • After death — with the consent of children and the surviving spouse, or of parents if there are none

    Voice

    • As of October 2026 there is no separate article on the voice in the Civil Code: the draft law on Art. 152.3 was introduced in 2024 and has not been adopted
    • In its response to it, the Government stated that a voice recording is biometric personal data and as a general rule requires consent

    What this means for the service

    • Consent is given by the owner of the face or voice, not by whoever uploaded the materials
    • An avatar or clone without consent is a dispute with the owner of the likeness, in which the service is liable
  • Personal and biometric data

    152‑FZ, Part 1 of Art. 9 (as amended by 156‑FZ), Part 1 of Art. 11; 572‑FZ, Art. 15.

    Verification checklist

    Separate consent

    • Since 1 September 2025, consent to personal data processing must be drawn up separately from the offer and the user agreement

    Biometrics

    • A face and a voice used to establish identity are biometric data: only with written consent
    • Collecting biometrics for identification outside the Unified Biometric System is prohibited for organisations — which processing is acceptable in your scenario is for a lawyer to decide

    Model training

    • Using a user's photos and recordings to train a model is a separate purpose, and it is named in the consent
  • The AI law and user sign-in

    Law of 26.07.2026 No. 243‑FZ, Arts. 9, 10 (from 1 March 2027); 149‑FZ, Part 10 of Art. 8; Administrative Offences Code, Art. 13.55.

    What the service risks

    Labelling

    • The author of an image, audio or video created by a large model gets the ability to mark the material
    • Large platforms with a daily audience of more than 500,000 people must give users such an ability

    Entry

    • A Russian website or app authorises users by phone number, through Gosuslugi, the Unified Biometric System or a Russian system
    • From 7 July 2026, signing in through foreign services carries a fine for a legal entity of 500,000 to 700,000 ₽

    What the law does not contain

    • There is no obligation to identify users of an AI service: the service chooses the level of verification by the risk of the feature

API, generation, voice, avatars and labelling: whom an AI service verifies and when

There is no need to verify everyone who comes in to try a neural network. Verification is needed where the service opens access to someone else's face or voice, to large limits or to money.

  • LLM and AI API providers

    • An organisation asks for extended limits, access to powerful models or payment by invoice
    • Company by tax number, head and founders, sanctions lists — before connection
    • Representative — document and Liveness, so that the keys do not go to an outsider
  • Image and video generation

    • A user uploads a photo of a person to “animate” it or insert it into a clip
    • For features with real faces — document, Liveness and matching the face against the uploaded photos
    • The selfie is checked for deepfake signs and face-swap
  • Voice synthesis and cloning

    • A voice clone is made from a few minutes of recording — someone else's voice is easy to take from social media
    • The voice owner goes through a KYC session, and the service links the recording and the consent
    • NeuroVision does not analyse the voice — we confirm the identity of the person who gives consent
  • Digital avatars and AI doubles

    • A presenter, blogger or teacher sells their avatar under a licence
    • The identity of the likeness owner and face matching on the source photos and videos
    • Re-verification for a new likeness and before royalty payment
  • Data labelling and AI training

    • Labellers, assessors and experts who evaluate model answers
    • Passport, adult age by date of birth, one person — one account by document number
    • Self-employed status — before payment
  • AI services: image generation, voice synthesis, avatars and data labelling

Consent to a digital likeness in three steps: document, Liveness and face matching against the materials

The likeness owner goes through user verification right in your AI service, from a phone or computer. You receive confirmation that the materials for the avatar or clip were uploaded by the same person who signed the consent.

Step 1

Consent and document

The likeness owner signs the consent as a separate step and photographs the passport with the camera. Full name, date of birth and document number arrive as fields without manual entry, and anti-fraud flags a photo of a screen, a printout and traces of editing.

Likeness owner's consent and passport recognition without manual entry
Step 2

Liveness and selfie

The person goes through Liveness: a photo, a screen, a mask and video stream substitution are rejected. The selfie is checked for signs of a deepfake, face-swap and full generation, and the face is compared with the photo in the document.

Liveness and a check of the likeness owner's selfie for deepfake signs
Step 3

Face matching against the materials

The face from the photos and video frames that the person uploaded for the likeness is compared with their face from the session. A match — the likeness is created; no match — the service stops it pending review. The decision and consent are stored with the session number.

Matching the likeness owner's face against photos and video frames for the avatar

A voice without an article in the Civil Code: how to record consent to voice synthesis

Voice and the law as of October 2026

What exists and what does not

  • 01

    Why the voice is harder than the face

    The image is protected by Art. 152.1 of the Civil Code; the voice is not yet: the draft law on Art. 152.3 has not been adopted since 2024. So the basis is the personal data law and the contract with the voice owner. The more precise the contract, the fewer disputes about what consent was given for.

  • 02

    Who gives consent

    Consent to a voice clone is given by the owner themselves, not by a studio, an agent or the user who brought the recording. The service makes sure it is them: the owner goes through a KYC session, and the service links the voice recording and the signed consent to the session number.

  • 03

    What to put in the consent

    Purposes separately: speech synthesis, model training, commercial use, advertising. The term, the territory, who else will get access to the model, and the withdrawal procedure. Training on recordings without a direct indication in the contract is a frequent cause of disputes between voice actors and clients.

  • 04

    Withdrawal of consent

    The owner has the right to withdraw consent to personal data processing. The service needs a clear procedure: switch off the voice, stop payments and delete the session data. A withdrawal should also be accepted from the verified owner — so that a stranger does not “withdraw” the likeness on their behalf.

  • Art. 152.1 a citizen's image — only with their consent
  • № 718834‑8 draft law on voice protection, not adopted
  • Part 1 of Art. 11 a face and a voice for establishing identity are biometrics

Verification checklist for an AI service: from registration to payment of a labeller

The level of verification grows with the risk of the feature. A free chat does not require a passport, while the avatar of a real person and a payment to a contractor do. This is a guide for a conversation with a lawyer, not a legal opinion; the rules are as of October 2026. How to protect personal and biometric data in KYC — in a blog article.

  • Sign-in by phone number, through Gosuslugi, the Unified Biometric System or a Russian authorisation system — without foreign sign-in services Law
  • Free limits — without a document; enable verification at the step where risk opens up Recommendation

  • Company by INN: status, head and founders, sanctions lists NeuroVision
  • Representative — document and Liveness before keys are issued NeuroVision

  • Consent of the face owner as a separate document, with purposes and term Law
  • Document, Liveness, face matching against uploaded photos and videos NeuroVisionAsk your lawyer

  • KYC session of the likeness owner, recording and consent — in one session RecommendationNeuroVision
  • Licence for the likeness: purposes, model training, term, territory, withdrawal Ask your lawyer

  • Passport and adult age by date of birth, one account per document number NeuroVision
  • Self-employed status — before every payment NeuroVision

  • The session data retention period is set in the scenario, and data is deleted on request NeuroVision
  • Withdrawal of consent — from the verified owner, after which the likeness is switched off Recommendation
  • Law — required by law
  • Recommendation — practice, not an obligation
  • NeuroVision — the step is covered by a NeuroVision check: result, source and date
  • Ask your lawyer — the limit of what is permissible is determined by the service's lawyer

Moderation, labelling, voice: what remains with the AI service

  • We do not moderate generated content

    Verification answers the question “who is this user and is it their face in the materials”. What they then generate is a matter of your service's usage policy, filters and moderation.

  • We do not check the voice

    NeuroVision works with the document and the face. We do not recognise a voice clone by sound — we confirm the identity of the person who gives consent, and linking the recording to the session is done by the service.

  • We do not replace the contract and consent

    The check proves that the consent was signed by the likeness owner. The text of the consent and licence, the purposes, terms and withdrawal procedure are prepared by your lawyer.

  • We do not label content

    Under 243‑FZ, the ability to mark AI-created material is provided by the platform. The label and its format are on the service's side.

How Liveness tells a live person from a deepfake, a mask and a virtual camera — on the page “Deepfake protection in verification”.

The decision to let a user into a feature or to stop a likeness is made by the service: NeuroVision provides the result of each check and the session number.

Re-verification in an AI service: when to ask for the document and Liveness again

  • A new likeness on an old account

    The avatar owner adds a new voice or new photos — Liveness and face matching against the new materials again. The account may have changed hands.

  • Before payment

    For a labeller or a likeness author — Liveness and self-employed status before transferring money. This shows that the money goes to the person who passed the check.

  • Change of organisation owner

    An API client's head or representative has changed — a company check and the new representative's document before the keys are renewed.

  • Complaint from a likeness owner

    A person reports that an avatar was made without their consent — the likeness is stopped, and the complainant goes through a KYC session so that the service can match their face against the materials.

A likeness owner's complaint: what it means for the service and what protects it

If an avatar or clip is made from someone else's photos, claims will be brought not only against the user but also against the service that distributed the image. The owner's confirmed consent is the main argument.

  • Delete and cease

    A citizen has the right to demand that an image distributed online without consent be deleted and further distribution be prohibited

    Copies bearing such an image are seized and destroyed by court decision

    • Civil Code of the Russian Federation, Art. 152.1
  • Compensation for non-pecuniary damage

    Violation of personal non-property rights gives the right to monetary compensation

    The amount is determined by the court; for a defamatory clip, protection of honour and business reputation is added

    • Civil Code of the Russian Federation, Arts. 151, 152
  • Personal data without consent

    Processing without consent or without separate consent — a fine for the organisation

    The amount is under the current version of Art. 13.11 of the Administrative Offences Code; a repeat violation costs more

    • Administrative Offences Code, Art. 13.11
  • Sign-in through a foreign service

    Authorising users by means other than those permitted by law

    For a legal entity — 500,000 to 700,000 ₽ from 7 July 2026

    • Administrative Offences Code, Art. 13.55

Checks for an AI service: catalogue and prices

The set is assembled for the feature: an avatar needs Liveness and face matching, an API client — a company check, a labeller — self-employed status.

The document with no manual entry

Document fields, anti-fraud and a check against the Ministry of Internal Affairs database.

  • OCR NeuroVision

    Document recognition

    The document is recognised from a photo: 16,000+ types from 195+ countries and territories, fields arrive without retyping. Included in the “Document” package.

    from 16 ₽

    Learn more
  • NeuroVision

    Document anti-fraud

    Signs of a photo of a screen, a printout, a pasted-in photo and traces of editing. Included in the “Document” package.

    in the package

    Learn more
  • Police · SMEV

    Validity of a Russian passport

    The authenticity and validity of a Russian passport through the interagency interaction system. It catches expired, replaced, lost and invalid documents and verifies that the passport was issued to this particular person.

    5 ₽ / check

    Learn more
  • Federal Tax Service

    INN by passport

    Determining the tax number from the passport data. It unlocks the checks that need precise identification of the person — with no namesakes.

    5 ₽ / check

    Learn more

How much it costs to verify a user of an AI service

No subscription fee: you pay for the sessions and checks performed. One KYC session is one person with all the steps of the scenario.

  • User with a document

    from 16 ₽ per session

    Build a set

    Document recognition and anti-fraud, date of birth and document number as fields — for labellers and features without a face. Database checks — 5 ₽ each.

  • For avatars and voice

    Consent to a likeness

    from 29 ₽ per session

    Calculate

    Document with anti-fraud, Liveness, deepfake and face-swap signs, comparison of the face with the document. At 10,000 sessions a year — 33 ₽; the price falls as volume grows.

  • Organisation for the API

    on request

    Enable

    Company by INN as part of the KYB scenario, head and founders — 5 ₽ per register, international screening — 36 ₽, representative — a “Document + Liveness” session.

Prices follow the price matrix on the publication date. Test access — 1 month.

Integration: a check at the likeness creation step, in the API console and before payment

Verification is built into the step where the user creates a likeness, requests limits or a payout, and the scenario is changed in the personal account without development.

Web SDK

The Web SDK is embedded in the service's website, and in a mobile app — through WebView: the widget captures the document, selfie and Liveness with the camera and shows prompts. The logo, colours and texts are customised for your service. Without development — a unique link to the check. Documentation

  • Web SDK
  • WebView
  • REST API
  • Unique link

Test access for 1 month.

Payment only for sessions performed; the data retention period is set in the scenario.

Why avatar, voice and labelling platforms choose NeuroVision

An AI service needs a check that will not put off an honest user and will withstand a dispute with the owner of the likeness.

Face, document and company — in one service

Document, Liveness, face matching against the materials and organisation checks work through one API and one session. For each likeness you have a session number and the result of each check.

There is no need to assemble a solution from several vendors and reconcile their responses.

A live person

Liveness rejects a photo, a screen, a mask and video stream substitution; the selfie is checked for a deepfake.

Document Liveness Face Company

Documents of the world

16,000+ types from 195+ countries and territories — for users from different countries.

Face comparison

The owner's face is matched against the materials for the likeness by an API request.

Skolkovo — participant

Data under control

The retention period is set in the scenario, and data is deleted on request.

AI service glossary: digital likeness, voice clone, large foundation model

Concepts that come up when an AI service works with the faces and voices of real people.

Digital likeness
A person's appearance and voice from which a model creates their image or speech. The term is not in the law: the image (Art. 152.1 of the Civil Code) and personal data are protected.
Digital likeness
Digital avatar
A model that speaks and moves like a specific person, built from their photos and videos.
Digital avatar
Voice clone
A speech synthesis model trained on recordings of a specific person.
Voice clone
Large foundation model
Under 243‑FZ — an AI model with at least 1 billion parameters that solves many different tasks.
Large foundation model
AI content labelling
A warning that an image, audio or video was created with the help of AI. Under 243‑FZ — an ability, not an obligation of the author.
AI content label
Liveness
A check that a live person is in front of the camera, and not a photo, a screen, a mask or a deepfake.
Liveness detection
1:1 face comparison
Comparison of two images, to determine whether it is the same person.
Face verification
Face swap
Replacing a face in the frame with someone else's, including in real time.
Face swap
Biometric personal data
Information about a person's physiological characteristics by which their identity is established — for example, the face and voice.
Biometric data
Data labelling
Preparation of data for AI training by people: captions, ratings, comparison of model answers.
Data annotation

Frequently asked questions about verifying users of AI services

By the risk of the feature. For free limits, sign-in by phone or Gosuslugi is enough. Before creating an avatar or voice clone — document, Liveness and face matching against the materials; before API access — a check of the company and its representative; before paying a labeller — Liveness and self-employed status.

No. Law No. 243‑FZ of 26 July 2026 on supporting AI technologies does not require users to be identified. Sign-in requirements are set by the Information Law: phone, Gosuslugi, the Unified Biometric System or a Russian authorisation system.

Yes. A citizen's image may be made public and used only with their consent (Art. 152.1 of the Civil Code). If the face is used to establish identity, it is also biometric data — written consent under 152‑FZ is required.

There is no separate article on the voice in the Civil Code as of October 2026: draft law No. 718834‑8 on Art. 152.3 has not been adopted. A voice recording is protected by the personal data law, so the voice owner's consent and a contract are needed even now.

No, we do not analyse the voice. We confirm the identity of the person who gives consent to the clone: document, Liveness and face in one session. The service links the voice recording and the consent to the number of that session.

Ask them to go through a KYC session: document, Liveness and selfie. Then the face in the uploaded photos and video frames is compared with the face from the session. No match — the likeness is stopped pending review.

Stop the likeness, invite the complainant to go through a KYC session and match their face against the materials. If the consent was signed by another person, delete the likeness and the data. The owner's confirmed consent is the service's main argument in a dispute.

Yes. Liveness rejects a photo, a screen, masks and video stream substitution, and the selfie is checked for deepfake and face-swap signs. In detail — on the deepfake protection page.

By INN: company status, head and founders, sanctions lists and, if necessary, international screening. The representative who receives the keys goes through a “Document + Liveness” session.

The document number and date of birth arrive as response fields — check them against your contractor database before the first task. Before payment, ask for a repeat Liveness and check the self-employed status.

The retention period is set in the check scenario; indefinite storage is enabled separately. Session data can be deleted on request — this matters if it holds photos and videos from which a likeness is made. The support mode and communication channels are fixed in the contract.

A “Document + Liveness” session — from 29 ₽, “Document” — from 16 ₽, database checks — 5 ₽, no subscription fee. Test access — 1 month.

We will select a verification scenario for your AI service

Tell us what your service does — API, generation, voice, avatars or labelling — and how many users go through verification per month. We will build a scenario for each feature and give you test access.

Can't put your request into words? Book a call and our team will contact you at a convenient time

Book a call

The company is included in the register of IT companies and the register of personal data operators of the Russian Ministry of Digital Development.

Address: Moscow, Presnenskaya Embankment 12 — Moscow City business centre, Federation Tower. Nearest metro stations: Delovoy Tsentr and Mezhdunarodnaya.