Denmark leads global push to protect human identity from ai exploitation
Dr Taimoor Ul Hassan
Copenhagen: In A Small Yet Significant Legislative Leap, Denmark Recently Etched Its Name Into The Digital Rights Frontier By Officially Recognising The Human Face, Body And Voice As Intellectual Property. This Groundbreaking Move Treats Personal Physical And Vocal Attributes Not Just As Biometric Data, But As Elements Of Identity Worthy Of Protection Under Copyright-Like Frameworks. By Placing Legal Ownership Over What Makes Us Visibly And Audibly Human, Denmark Has Initiated A Global Conversation That Transcends Privacy And Enters The Terrain Of Identity Sovereignty. It Marks One Of The Most Assertive Governmental Responses Yet To The Evolving Deepfake Dilemma.
Deepfakes, Once Niche Experiments Of AI Laboratories, Have Now Become Chillingly Sophisticated Tools That Replicate Facial Expressions, Vocal Inflections And Even Body Language With Uncanny Precision. These Synthetic Media Forms Threaten Not Only Personal Dignity But The Very Scaffolding Of Democratic Trust. Elections, Courtrooms, Newsrooms And Classrooms Are All Vulnerable To Deception On An Industrial Scale. Denmark’S Legal Shift Acknowledges The Personal As Proprietary, Thereby Laying The Foundation For Judicial Recourse When Digital Mimicry Trespasses Into Exploitation Or Fraud.
This Move Has Resonated Globally. In The European Union, The Proposed Artificial Intelligence Act, Currently Under Trilogue Negotiation, Includes Provisions To Categorise Deepfakes As High-Risk AI. The Act Will Require Clear Labelling Of Synthetic Content And Introduce Penalties For Unlabelled Or Malicious Uses. It Also Mandates Transparency In Datasets Used To Train Generative Models, Thereby Addressing The Root Of The Issue: AI Trained On Publicly Scraped Human Content Without Consent.
Germany Has Taken A Slightly Different Route. Recognising The Threat To Public Discourse, It Has Empowered Its Federal Cybersecurity Agency To Monitor And Flag Synthetic Media During Elections. In France, Where Reputational Damage Can Easily Translate Into Defamation Suits, Courts Have Already Begun Processing Deepfake-Related Complaints Under Existing Laws Of Identity Theft And Personal Harm. These Responses, Though Varied, Converge On The Urgency To Reassert Legal Boundaries In The Age Of Algorithmic Simulation.
In The United States, Responses Remain Patchwork But No Less Revealing. California And Texas Were Among The First To Introduce Laws Criminalising Deepfakes In Political Campaigning And Non-Consensual Pornography. The DEEPFAKES Accountability Act, Introduced At The Federal Level—Though Still Under Debate—Proposes Watermarks For All Synthetic Media And Envisions Severe Penalties For Deceptive Use, Especially In News And Electoral Content. More Recently, The Federal Trade Commission Has Signalled Its Intent To Treat Deceptive Synthetic Media As A Form Of Consumer Fraud, Placing It Under The Agency’S Regulatory Lens.
Interestingly, The Entertainment Industry In The United States Has Become An Unintentional Pioneer. The 2023 Actors’ And Writers’ Strike Brought To Light The Use Of AI To Replicate Performers’ Voices And Likenesses. In A Rare Display Of Solidarity, The Screen Actors Guild Negotiated For Contractual Rights Over Digital Replicas Of Actors. Studios Now Require Explicit Consent Before Using AI-Generated Versions Of Performers, And These Clauses Have Been Enshrined In Formal Agreements. Hollywood’S Friction With AI Has Perhaps Advanced Legal Thinking On Synthetic Identity Faster Than Most Legislative Corridors.
In The Asia Pacific, South Korea—With Its Digitally Hyperconnected Society—Has Emerged As A Testing Ground For Regulation. Its Communications Commission Has Mandated That All Deepfakes Be Clearly Labelled In Media And Has Imposed Fines For Unmarked Synthetic Content. The Ministry Of Justice Is Also Drafting Amendments To Its Information And Communications Network Act To Define And Penalise Harmful AI-Generated Content More Precisely. Meanwhile, China, Known For Aggressive Content Regulation, Now Requires All Synthetic Content To Bear Digital Watermarks And Bans Deepfakes That Distort Political Or Historical Narratives. These Measures May Be State-Centric, But They Illustrate An Emerging Consensus That Digital Mimicry Must Be Restrained Before It Unmoors Social Stability.
In A Noteworthy Cross-Continental Move, Australia Has Invested In Public Awareness Campaigns Alongside Legal Tools. Its ESafety Commissioner Has Issued Toolkits For Schools, Parents And Journalists To Identify And Counter Deepfake Content. Australia Also Offers Individuals A Right To Delisting Or Takedown Of Manipulated Images Or Videos—Especially Those Related To Intimate Content—From Search Engines And Platforms. This People-First Strategy Combines Regulation With Empowerment And Underscores That Deepfakes Are Not Merely A Technological Challenge But A Societal One.
Pakistan, Too, Cannot Remain Untouched. The Country Has Already Witnessed Cases Where AI-Generated Female Images Were Circulated To Defame Political Workers And Journalists. While Pakistan’S Prevention Of Electronic Crimes Act Covers Cyberstalking And Image Tampering, The Law Does Not Yet Address Synthetic Identities In Their Full Digital Complexity. There Is An Urgent Need For Legal Reform That Includes Recognition Of Biometric Likeness As Personal Property, Penalties For Political Manipulation Via Deepfakes, And AI Literacy Initiatives For Public Awareness. If Not Pre-Empted By Law And Media Policy, Synthetic Disinformation Could Deepen Polarisation And Erode What Little Trust Remains In Public Discourse.
Globally, Tech Platforms Remain Both Complicit And Critical. Meta, Google And TikTok Have Taken Steps To Label Or Remove Manipulated Media, But Their Methods Are Inconsistent And Often Reactive. OpenAI, Anthropic And Other Frontier AI Labs Have Now Signed Voluntary Agreements With Governments To Watermark Their Generated Content, But Watermarking Is Not A Foolproof Solution. Deepfake Detectors Are Already Lagging Behind Generator Models In The Technological Arms Race. This Asymmetry Has Led To Calls For AI Models To Be Open To External Audits And For Governments To Enforce Traceability Mechanisms Through Legal Mandates Rather Than Industry Goodwill.
Yet, Amid This Legal And Technical Combat, A Deeper Philosophical Question Lingers. What Does It Mean To Be Human In An Era Where One’s Face, Voice And Gestures Can Be Infinitely Copied And Weaponised? The Struggle Against Deepfakes Is Not Just About Preventing Electoral Fraud Or Protecting Celebrities. It Is About Preserving The Authenticity Of Presence, The Credibility Of Memory, And The Sanctity Of Speech. In Reclaiming Control Over Our Digital Doubles, Nations Are Slowly Converging On A Principle That Should Have Always Been Self-Evident: To Be Human Is To Own Oneself.
As Deepfakes Grow More Persuasive, The World Seems To Be Waking Up Not Just To The Threat Of Disinformation But To The Larger Project Of Digital Personhood. The Struggle Against Deepfakes Is Not Just About Technology—It’s About Reclaiming What It Means To Be Human In The Digital Age. Denmark’S Bold Step May Appear Symbolic, But It Charts A Path Forward. In Time, The Face In The Mirror Will Not Just Reflect Who We Are, But What We Legally Own.
