New York’s Fashion Workers Act is entering a new phase, as the law’s one-year registration period for model management companies officially comes to an end. As of June 19, the statutory one-year period for model management company registration under the Act has expired, moving the law into a more consequential compliance phase for agencies and management companies operating in the state. While the Act’s substantive workplace protections began taking effect on June 19, 2025, the close of the registration period sharpens the focus on which companies are formally registered with the New York Department of Labor.
Enacted in 2025, the Fashion Workers Act created a statutory regime governing model management companies and, to a lesser extent, the brands, retailers, photographers, and other clients that engage models in New York. The law requires covered model management companies to register with the New York Department of Labor, pay a fee, and, in some cases, post a $50,000 surety bond. It also imposes a range of obligations relating to contracts, payment practices, workplace protections, and the creation or use of digital replicas, including AI-generated or AI-altered depictions of models.
The significance of the registration deadline lies less in the filing process itself than in what it signals about enforcement. Registration creates a public-facing mechanism for identifying which companies are operating as model management businesses in New York, while also giving the state a clearer pathway to monitor compliance with the Act’s broader requirements. Those include a 20 percent commission cap, restrictions on contract renewals and deductions, advance disclosure obligations, and separate written consent requirements for the creation or use of a model’s digital replica.
>> The timing is notable given that disputes over AI-generated model likenesses are already reaching the courts. Model Francheska Pujols refiled a lawsuit in New York state court this month against Rainbow Shops, alleging that the retailer used AI-generated images of her likeness in ads without authorization and in ways that exceeded the scope of her original agreement. A separate but similar lawsuit was waged in California federal court by model Molly Tranchin.
While the Act does not resolve the merits of those disputes, the cases still illustrates the kinds of consent, contract, and digital-replica questions the law was designed, at least in part, to address as AI tools become more deeply embedded in fashion marketing and e-commerce.
For brands and other fashion businesses, the deadline is a reminder that the Act is not limited to agencies. Clients that engage models through management companies are subject to certain obligations of their own, including overtime, meal break, insurance, and anti-harassment requirements, while the statute’s broad definitions and enforcement provisions leave open unresolved questions about the scope of potential client liability. In that sense, the registration deadline is less an administrative milestone than a marker of New York’s effort to formalize a labor and compliance framework for a sector that has historically operated with relatively little regulatory oversight.
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