Big news coming into the new year: we now have the full text of the newly ratified SAG-AFTRA Interactive Media Agreement (IMA). 

As a brief refresher, we covered SAG-AFTRA’s announcement back in July 2025 that its members ratified the updated IMA – we have the full text of the agreement, referred to now as the ‘2022-2028 Memorandum of Agreement.’  While increased wages and new safety protocols are significant, the notable changes are how the IMA handles artificial intelligence.

If you were familiar with the Summary of the IMA released by SAG last June, you won’t be surprised by the full terms of the IMA which are consistent therewith.  Below, we’ve broken down a few of the key updates in the latest IMA:

Artificial Intelligence: Differentiating the Tech

Perhaps the most significant addition to the 2025 IMA is its inclusion of certain protections and obligations in connection with the use of AI. Before diving into the rules, it is important to understand what the new agreement actually covers. The IMA distinguishes between several forms of AI technology to ensure specific protections:

• Generative AI (GAI): This refers to AI that learns patterns from data to produce new content, like ChatGPT or MidJourney.

• Digital Replicas: These are the specific AI-generated versions of a performer’s voice or likeness used in place of that performer, which we further detail below.

• Traditional / Permitted AI: The IMA explicitly excludes from these new requirements "traditional AI" technologies that are programmed for specific functions like character animation, as well as "Processing Practices" like noise reduction, pitch adjustment, and character rigging. These standard development tools do not require the same consent and compensation as replicas.

What counts as a “Digital Replica”?

The IMA breaks digital versions of performers into a few specific categories, Digital Replicas and Independently Created Digital Replicas (ICDRs):

• Digital Replicas include two categories:

  • Vocal Digital Replicas: AI-generated voices created primarily from a performer’s union-covered work to generate new dialogue.

  • Visual Digital Replicas: Digital versions of a performer’s physical likeness used to create new scripted cinematic content.

• ICDRs are replicas made using non-union material or by prompting a GAI system with a performer’s name.

Vocal Digital Replicas and Visual Digital Replicas are essentially treated as extensions of the performer’s actual performance and are tightly regulated by the IMA. ICDRs are regulated differently, but still require consent and bargaining in most cases. Each of these digital AI uses also comes with new calculation standards for payment. For example, if an employer uses a Vocal Digital Replica of a performer, that performer must get paid based on the number of lines generated, with one “line” defined as roughly ten words. Employers will have to careful track not only the types of Digital Replicas being used, but also the new compensation obligations that attach. 

The “Informed Consent” Standard

Consent is no longer just a checkbox or broad blanket statement in a contract. The IMA now requires “clear and conspicuous” writing that is either a separate document or a specifically signed rider. Under these rules, employers have to provide a “reasonably specific description” of the use of the Digital Replica. This includes whether the replica will be used for “Real-Time Generation” (like an AI chatbot) and whether the performer will be asked to deal with sensitive content like profanity or racial slurs.

Importantly, for most uses, employers cannot grab this consent at the time of initial employment for future games. They have to come back and negotiate later, which protects performers from being pressured into broad rights grabs before they even start the job.

Reporting Requirements

Employers also have to provide a usage report within 90 days of a game’s release. This report must detail which characters used a Digital Replica and how the performer’s compensation was calculated.

What Else? 

While the addition of AI terms may have been of the most significant updates to the IMA, it was not the only one.  Indeed, some of the other more pertinent updates include:

• Contract Term: The IMA runs for six years, from November 8, 2022 through October 31, 2028.

• Wage Increases: Minimum scale rates increase on a compounded basis as follows (which apply across covered performer categories, excluding certain bonus based compensation):

  • 15.17% increase upon ratification

  • 3% effective November 1, 2025

  • 3% effective November 1, 2026

  • 3% effective November 1, 2027

• Additional Compensation Increases: Additional Compensation for Principal Performer recording sessions 7 through 10 increase from $275 to $285 per session. This change modestly raises back end compensation tied to session volume without restructuring the existing bonus framework.

• P&H Contribution Increases: Employer contributions to performer benefits increase over time as follows, which represents a continued shift toward higher benefit funding while maintaining predictable step increases:

  • 17% effective upon ratification; and

  • 17.5% effective October 31, 2026.

• Late Payment / Liquidated Damages: The IMA tightens payment mechanics and clarifies penalties:

  • Performers must be paid within 12 business days after services are rendered or paperwork is completed, whichever is later;

  • Limited tolling applies if required paperwork is delayed; and

  • Liquidated damages apply for late payment and escalate if nonpayment continues after notice.

• Overtime:

  • For performers paid double scale or more, overtime is capped at double scale, providing clarity on overtime exposure for higher paid performers.

  • The agreement allows limited prepayment of overtime for overscale performers, subject to strict conditions:

    • Available only at higher compensation thresholds;

    • Must be clearly disclosed in writing; and

    • Caps the number of prepaid overtime hours per day.

Looking Ahead

If nothing else, the 2025 IMA gives everyone something to agree on: the rules are clear(er), the stakes are higher, and no one should pretend they didn’t see this coming. If you work in interactive media long enough, you eventually learn that contracts do not get shorter, but they do get more specific. This one is no exception. At the end of the day, the 2025 IMA is now the water we are all swimming in. You do not have to love it, but you should strive to understand it.  Hopefully, this blog has helped with that task.

On a final note, and in addition to the 2025 IMA, we have continued to see state laws enacted, such as with California AB 2606, which similarly attempts to address protecting performers. Employers covered by the IMA, through their compliance efforts, will be ahead of the game.