Mexico - Protect Dubbing Actors (2025)

Overview

The Proyecto de Decreto, introduced on 24 April 2025, proposes targeted amendments to the Ley Federal de Cinematografía, the Ley Federal del Derecho de Autor and the Ley Federal del Trabajo to respond to the rapid deployment of voice-synthesis and generative audio AI technologies. The measure's central objective is to protect the labor, cultural and intellectual property rights of dubbing performers by (a) requiring informed written consent and fair compensation for AI-based replication of voices; (b) prohibiting exclusive substitution of human performers with AI without contractual authorization; and (c) requiring public disclosure when AI is used in a dubbing performance. The text of the initiative is publicly accessible in the Chamber of Deputies' official Gaceta Parlamentaria. For the official initiative text see Gaceta Parlamentaria, 24 April 2025.

Definitions

The proposed changes introduce and clarify defined terms for legal and operational certainty. Relevant definitions include: "AI-generated voice" (any voice audio obtained primarily by algorithmic synthesis rather than live human performance); "cloning, emulation or simulation" (the creation of a sound recording intending to reproduce the timbre, prosody or identifiable performance characteristics of an existing human performer); "consent" (prior, informed and written authorization by the rights holder); "compensation" (monetary remuneration proportionate to the commercial use; may include contributions to a designated cultural fund); "public disclosure" (clear labelling or credits when AI is used for a performance); and "dubbing production" (audiovisual projects employing voice-over artists for localization or performance). These definitions align intellectual property, labor and cultural policy objectives and are intended to reduce ambiguity in enforcement and contract drafting.

Governance and Institutional Framework

The initiative creates a multi-agency governance approach. Primary administrative responsibilities fall to the Secretaría de Cultura (for sectoral cultural policy and administration of the proposed compensation fund), the Instituto Nacional del Derecho de Autor (INDAUTOR) (for registration, advisory and enforcement in copyright matters), and the Secretaría del Trabajo y Previsión Social (STPS) (for labor inspection, contract compliance, and sanctions). The bill mandates coordination between these agencies and the Chamber of Deputies' oversight committees to issue guidance, publish model contractual clauses and provide capacity-building to studios and unions. The Gaceta entry contains the formal initiative; see the official publication at Gaceta Parlamentaria. Coordination mechanisms are designed to balance cultural promotion with labor protection while providing a central administrative route to receive complaints and to adjudicate administrative infractions.

Key Focus Areas

The draft focuses on four substantive areas. First, Intellectual Property: the Ley Federal del Derecho de Autor is amended to specify that AI-based cloning of a dubbing performer's fixed performance constitutes a protected interest requiring prior written authorization; unauthorized cloning is not a valid disclosure and cannot be presented as the performer's authorized work. Second, Labor Protections: the Ley Federal del Trabajo would require explicit clauses in employment or service contracts regarding AI use, consent and remuneration, with unauthorized use treated as a violation of labor rights subject to sanction. Third, Cultural Policy and Cinematography: the Ley Federal de Cinematografía will prioritize in-country dubbing with living Mexican professionals and prohibit exclusive AI substitution without written authorization, aiming to preserve linguistic identity and jobs in the national dubbing industry. Fourth, Transparency and Disclosure: any public use of AI in voice performance must be communicated to the public to prevent consumer deception and preserve artistic integrity.

Implementation Framework

Implementation is envisioned through a combination of regulatory guidance, model contractual clauses and enforcement pathways. The Secretaría de Cultura is tasked with creating a fund financed by mandated contributions from commercial uses of AI-generated voices; the INDAUTOR will provide advisory services and maintain registries or guidance on licensing of AI-voices; the STPS will integrate AI-use clauses into labor inspection checklists and impose fines where violations occur. The bill proposes appropriate updating of inspection protocols and an outreach program for small and medium dubbing studios to facilitate compliance. Producers must be able to demonstrate compliance as part of production licensing and may be required to declare whether synthetic voices were used for a given title.

Monitoring and Evaluation

Monitoring will combine sectoral reporting, labor inspections and public complaints procedures. The draft requires periodic reports from the Secretaría de Cultura and INDAUTOR to the relevant Congressional committees on enforcement activity, fund disbursement and the impact on employment in the dubbing sector. Key performance indicators include number of unauthorized uses detected, number of contracts updated with AI clauses, funds collected and distributed, and qualitative assessments of the impact on employment and cultural outputs. Third-party audits and evaluations may be commissioned to ensure transparency and that the measure does not unintentionally hinder access to legitimate creative uses of synthetic voices with consent.

Penalties, Liability, and Appeals

The draft introduces administrative fines and labor sanctions for unauthorized use of AI to replicate or substitute workers' voices. The bill proposes fines ranging from 1,000 to 5,000 UMAs for employers who use AI to replicate or substitute the voice of workers without authorization (per the amendment to Article 994 proposed in the initiative). Liability includes obligations to pay proportional remuneration, potential civil damages under copyright law, and corrective measures such as takedown or rectification of credits. The initiative preserves existing judicial and administrative appeal routes; affected performers may seek labor remedies through STPS procedures and moral/patrimonial redress through INDAUTOR processes and civil courts where applicable.

Relationship to Other Instruments

The proposed amendments interact with existing national instruments including the Ley Federal de Protección de Datos Personales en Posesión de los Particulares (for voice as potentially sensitive biometric data), telecommunications and copyright statutes, international treaties on copyright (e.g., Berne Convention obligations), and possible forthcoming national AI policy. The draft recognizes that rights and obligations under international agreements remain applicable and that contractual freedom may allow different terms if explicitly agreed by parties, provided they do not contravene minimum protections established by the decree.

International Alignment

The initiative is consistent with global trends to protect performers' rights and respond to AI risks while preserving lawful innovation. Comparable regulatory efforts in other jurisdictions (for instance EU AI Act debates, recent proposals to protect artists in Spain, and voluntary industry codes) inform the draft's approach to consent, disclosure and proportionate remuneration. The bill stresses alignment with Mexico's international copyright obligations and indicates that exceptions may be required by binding international treaties. The drafters indicate awareness of international best practices while asserting the necessity of Mexico-specific protections for cultural and labor policy reasons. See INDAUTOR guidance and related cultural policy information at INDAUTOR Comunicados and relevant cultural policy pages at Secretaría de Cultura.

Implementation Timeline

Sources and References