“As someone that’s been in this industry since a teenager, watching the Act take shape has been incredibly meaningful. I have been a victim of mistreatment and the pressure to accept things that shouldn’t be normal. This Act feels like a turning point. We matter. Our bodies are not for sale, and we deserve to feel safe, respected, and fed like any other professional.” – Fatima Bathily, New York model
As of 19 June 2025, New York’s Fashion Workers Act is now fully in effect, marking a decisive shift in how the state’s fashion sector will be governed. After years of minimal oversight, the new law imposes clear, enforceable duties on agencies, model management groups and clients. The Act’s framework aims to eliminate hidden costs, tighten consent rules for digital replicas, and ensure models are treated, and paid, as the professionals they are.
Who the New York Fashion Workers Act Covers
A Model
Under the Act, a model is any independent person or employee who appears live or on social media, providing modelling services such as photoshoots, runway walks, posing or any artistic expression for advertising or display. This definition covers all stages of the work, including castings, fittings and showroom appearances.
A Management Company or Group
A model management company is any person, business or organisation that secures or tries to secure modelling work for a fee, or provides paid guidance or counselling to help a model secure work. If two or more such companies share common ownership, they form a model management group under the Act.
A Client
A client is any person, business or organisation that hires models directly, through an intermediary or via a model management company.
Duties for Management Companies and Groups
What They Must Do
- Starting 19 June 2025, every model management company doing business in New York must:
- Act with honesty and integrity and in the best interest of every model they represent.
- Use due diligence to ensure models are not placed in unreasonable danger.
- Maintain a clear written policy protecting models from abuse, harassment and inappropriate conduct, and share this policy with all models.
- Comply with Section 52-c of the New York Civil Rights Law for any work involving nudity or sexually explicit material.
- Obtain informed and voluntary written consent from the model before developing, selling or sharing any sexually explicit material involving the model’s intellectual property.
- Provide a written or digital deal memo before work begins, setting out total pay, pay period and agreed details.
- Provide the final booking agreement within seven days of the booking’s end, in the language the model requests, with best efforts made to sign it before work starts.
- Clearly explain any deductions that will be made from pay and secure the model’s approval before making upfront payments that will be recouped later.
- Inform models of any financial connections between the management company and the client.
- Notify former models in writing about any royalties owed after representation ends.
- Obtain separate, clear written consent before creating or using any digital replica (AI or computer-generated). This consent must specify scope, purpose, pay rate and period of use and must be separate from the main representation contract.
Note: Registration requirements for model management companies and groups will come into force from 21 December 2025.
What Management Companies Must Not Do
Management companies and groups are prohibited from:
- Charging any fee simply to sign a representation agreement.
- Requiring a power of attorney agreement as a condition for representation; if used, it may cover only modelling services and not digital replicas.
- Securing accommodation, such as shared apartments or hotels, without providing advance notice of the expected rent or rates before the model’s stay begins.
- Deducting money from a model’s pay unless agreed in the contract or confirmed in writing through an itemised list.
- Paying for a model’s travel or transport upfront expecting repayment later without prior written consent.
- Developing, altering or manipulating a model’s digital replica without separate written consent.
- Requiring a representation contract longer than three years.
- Enforcing automatic contract renewals without the model’s written approval.
- Charging commission fees that exceed twenty per cent of the model’s total pay.
Duties for Clients
- Clients, including brands, designers and production companies, must comply with several new duties:
- Pay models time and a half (1.5×) for any hours worked beyond eight in a twenty-four-hour period.
- Allow a meal break of at least thirty minutes for shifts lasting over eight hours in a day.
- Ensure that employment conditions do not expose models to unreasonable risk.
- Keep and share a written policy that aligns with New York State law on abuse, harassment and inappropriate behaviour.
- Ensure that any work involving nudity or sexually explicit content complies with Section 52 c of the Civil Rights Law.
- Allow models to bring an agent, manager or other representation to any job, engagement or performance.
- Provide liability insurance to protect the health and safety of models on assignment.
- Obtain clear, separate written consent before creating or using any digital replica, with full details on scope, purpose, rate of pay and duration.
A Measurable Step Forward
With the Fashion Workers Act now in force, the state’s modelling industry enters a new phase of enforceable accountability. Agencies, management groups and clients alike face clear legal duties that promise fairer pay, greater transparency and stronger protection for the models whose work sustains the industry’s visibility and value. Whether other states choose to follow New York’s lead remains to be seen, but within its borders, the expectations have changed.
Author: Assy Sy & Yael | Research: Assy Sy | Editor: Qazi
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