Vermont Synthetic Media in Elections Act (S.23 / Act 75): AI Compliance Requirements
Vermont's S.23 (Act 75), "An act relating to the use of synthetic media in elections," was signed by Governor Phil Scott on March 5, 2026 and took effect on passage. It requires a clear disclosure when deceptive synthetic media (AI-generated or digitally manipulated audio, video, or images) depicting a real candidate is used in election-related communications within 90 days of a Vermont election, where the person knows the media is deceptive and fraudulent and uses it with the intent to deceive voters. The required disclosure is the verbatim statement: "This media has been manipulated or generated by digital technology and depicts speech or conduct that did not occur." For images and video the disclosure must be clearly legible (and for video must appear for the full duration); for audio it must be clearly spoken at the beginning and end and at least every two minutes in longer recordings. Satire and parody are exempt. The Act is codified at 17 V.S.A. chapter 35, subchapter 4 (synthetic media in elections) and subchapter 5 (enforcement and additional remedies). Conservative best practice: clearly labeling all AI-generated political media (not only media intended to deceive) avoids any dispute over intent. It is among Vermont's first binding AI-specific laws.
Summary of publicly-available regulatory text as of 2026-08-22. Verify against current official sources before relying on this for compliance decisions. Not legal advice.
Key Facts
March 5, 2026
Enforced by the Vermont Attorney General under the Vermont Consumer Protection Act (9 V.S.A. ch. 63, via 17 V.S.A. ch. 35 subch. 5); a candidate depicted by deceptive synthetic media may bring a civil action for injunctive or other equitable relief. Cycle 21 (2026-08-22) resolved RQ-98's open civil-penalty figure via the CPA's own text: 9 V.S.A. § 2458 authorizes the AG to seek, alongside injunctive relief, a civil penalty of up to $10,000 for each unfair or deceptive act or practice, restitution, and reimbursement of the State's investigation/prosecution costs; § 2461 separately imposes up to $10,000 per violation of an injunction issued under § 2458. (No S.23/Act-75-specific penalty figure exists — exposure runs through these general CPA provisions.)
What Your Business Must Do
1 compliance requirement identified. Critical requirements carry the highest risk of enforcement action.
Synthetic-Media Election Disclosure (Vermont S.23 / Act 75)
High PriorityIf, within 90 days of a Vermont election, you create, distribute, or finance election-related communications that use deceptive synthetic media (AI-generated or digitally manipulated audio, video, or images) depicting a real candidate — and you know the media is deceptive and fraudulent and use it with the intent to deceive voters — you must include the verbatim disclosure: "This media has been manipulated or generated by digital technology and depicts speech or conduct that did not occur." For images and video the disclosure must be clearly legible (and for video must appear for the full duration); for audio it must be clearly spoken at the beginning and end and at least every two minutes in longer recordings. Satire and parody are exempt. Applies across all Vermont elections (governor, legislature, and local offices). Conservative best practice: label all AI-generated political media — not only media intended to deceive — to avoid any dispute over intent.
Deadline: March 5, 2026
17 V.S.A. ch. 35 subch. 4-5; enforcement via 9 V.S.A. §§ 2458, 2461Who Does This Apply To?
Applies to anyone who creates, distributes, or finances election-related communications in Vermont that use deceptive synthetic media (AI-generated or digitally manipulated audio, video, or images) depicting a real candidate, within 90 days of an election, where the person knows the media is deceptive and fraudulent and uses it with the intent to deceive voters, under S.23 / Act 75 (codified at 17 V.S.A. ch. 35 subch. 4–5). In scope means including the verbatim disclosure "This media has been manipulated or generated by digital technology and depicts speech or conduct that did not occur" — clearly legible for images/video (full duration for video) and clearly spoken at the beginning, the end, and at least every two minutes for longer audio — across all Vermont elections (governor, legislature, and local offices). Satire and parody are exempt. Enforcement is by the Vermont Attorney General under the Consumer Protection Act, and a depicted candidate may bring a civil action for injunctive or other equitable relief. Conservative best practice is to label all AI-generated political media regardless of intent. Scope turns on the deceptive election-media use, not company size.
Recent Regulatory Guidance
Vermont S.23 (Act 75) — Synthetic Media in Elections, signed March 5, 2026
Governor Phil Scott signed S.23 ("An act relating to the use of synthetic media in elections," Act 75) on March 5, 2026, effective on passage. Within 90 days of a Vermont election, election-related communications that use deceptive synthetic media (AI-generated or digitally manipulated audio/video/images) depicting a real candidate — where the person knows the media is deceptive and fraudulent and intends to deceive voters — must carry the verbatim disclosure "This media has been manipulated or generated by digital technology and depicts speech or conduct that did not occur" (legible for image/video, full duration for video; spoken at the beginning, end, and every two minutes for longer audio). Satire and parody are exempt. Codified at 17 V.S.A. ch. 35 subch. 4 (synthetic media) and subch. 5 (enforcement/remedies): enforced by the Vermont Attorney General under the Consumer Protection Act, with a depicted candidate able to seek injunctive or other equitable relief.
Key Case Law & Precedent
FCC AI-Robocall Declaratory Ruling (February 2024)
US Federal Communications Commission · 2024FCC unanimously declared that AI-generated voice in robocalls is an 'artificial voice' subject to TCPA restrictions. This federal-level ruling is the foundational precedent state AGs (including Vermont) rely on when extending consumer-protection authority to AI-generated political audio targeting voters via phone or messaging.
Outcome: AI-generated voice classified as 'artificial' under TCPA, immediately enforceable
Case referenceIndustry Playbooks covering Vermont Synthetic Media in Elections Act (S.23 / Act 75)
These industry playbooks include jurisdiction-specific checklist items and guidance for Vermont Synthetic Media in Elections Act (S.23 / Act 75).
Frequently Asked Questions
Does Vermont Synthetic Media in Elections Act (S.23 / Act 75) apply to my business?
Vermont's S.23 (Act 75), "An act relating to the use of synthetic media in elections," was signed by Governor Phil Scott on March 5, 2026 and took effect on passage. It requires a clear disclosure when deceptive synthetic media (AI-generated or… Use Aegis Firma's free scanner to get a personalized assessment in under 5 minutes.
What is the penalty for non-compliance?
The maximum penalty under Vermont Synthetic Media in Elections Act (S.23 / Act 75) is: Enforced by the Vermont Attorney General under the Vermont Consumer Protection Act (9 V.S.A. ch. 63, via 17 V.S.A. ch. 35 subch. 5); a candidate depicted by deceptive synthetic media may bring a civil action for injunctive or other equitable relief. Cycle 21 (2026-08-22) resolved RQ-98's open civil-penalty figure via the CPA's own text: 9 V.S.A. § 2458 authorizes the AG to seek, alongside injunctive relief, a civil penalty of up to $10,000 for each unfair or deceptive act or practice, restitution, and reimbursement of the State's investigation/prosecution costs; § 2461 separately imposes up to $10,000 per violation of an injunction issued under § 2458. (No S.23/Act-75-specific penalty figure exists — exposure runs through these general CPA provisions.). Fines are typically scaled by company size, severity of violation, and whether violations were willful or accidental.
How do I comply with Vermont Synthetic Media in Elections Act (S.23 / Act 75)?
The 1 requirements above cover the core obligations. The fastest path to compliance is: (1) conduct an AI risk assessment, (2) document your AI systems, (3) implement transparency disclosures where required. Aegis Firma generates all required documents automatically.
Official Source
https://legislature.vermont.gov/bill/status/2026/S.23Last updated: 2026-08-22 — verify at source before relying on this information.
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