If you have ever booked a model directly for a lookbook, a runway show, or an e-commerce shoot in New York, you are not a bystander to this law. You are a "client," with a defined set of duties, and the New York Department of Labor is now the agency that gets to decide whether you met them. I have watched this bill move through Albany for three years, and now that it is in force, the question I get most from small labels is simple: does this apply to me if I am not an agency, I am just hiring a model for a day? The answer is yes.
What changed
Governor Hochul signed the Fashion Workers Act into law on December 21, 2024, adding a new Article 36 to the New York Labor Law. The New York State Fashion Workers Act establishes new responsibilities and requirements for model management companies, model management groups, and clients, and it also establishes new workplace protections for models. The law rolled out in two phases. Starting June 19, 2025, model management companies, model management groups, and clients had to comply with all responsibilities and prohibited actions listed in the law, except those related to registration. Starting December 21, 2025, model management companies and model management groups had to register with the New York State Department of Labor and comply with any registration-related requirements. That registration window has now closed, and as of that date, 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. The protections apply whether the model is treated as an employee or an independent contractor, which closes the loophole agencies have used for decades. On the agency side, the law imposes a fiduciary duty, bars signing fees, caps representation agreements at three years, prohibits forced automatic renewal, and requires a deal memo listing full compensation before the model starts work. Any pre-existing power of attorney clause that does not meet the law's requirements is now void.
Who it affects
The law's definition of "client" is wide, and it names designers specifically. A client is a broad category that encompasses retail stores, designers, manufacturers, photographers, publishing companies, or any other person or entity that receives modeling services from a model, directly or through intermediaries. That means a two-person label booking one model through a New York agency for a single campaign is squarely inside the statute. As a client, you now have direct obligations, not just obligations that flow through your booking agency. You must provide a 30-minute meal break for any employment that exceeds eight hours in any 24-hour period, and compensate models at an hourly rate at least 50% higher than their contracted rate for anything that exceeds eight hours. You must establish a company policy that conforms with current New York State laws to address abuse, harassment, and any other inappropriate behavior towards models, shared with models in writing, and provide liability insurance to cover and ensure the health and safety of models. You must also allow models to bring their agent, manager, chaperone, or other representative to any engagement. None of this depends on whether you consider yourself a fashion "company" in the corporate sense. If you receive modeling services in New York, the duties attach. Geography matters too: the overtime and meal break rules generally apply when the work is physically performed in New York or the engagement is governed by a New York-based contract, so a shoot in Los Angeles for a New York label is a separate analysis.
What to do about it
Start with the piece that matters most for anyone reading this site: digital replicas. Digital replica means a significant, computer-generated, or artificial intelligence-enhanced representation of a model's likeness, including but not limited to their face, body, or voice, which substantially replicates or stands in for the real person. If you plan to use AI tools to extend a shoot, generate additional poses, or create synthetic imagery of a model you booked, you need clear and conspicuous prior written consent for any creation or use of a model's digital replica, detailing the scope, purpose, rate of pay, and duration of such use. This has to be a separate, explicit consent, not a line buried in a booking confirmation. Second, confirm the agency you are booking through is actually registered. Ask for the certificate. If they cannot produce one, that is now a real red flag, not just an administrative gap. Third, put your anti-harassment policy in writing and hand it to every model before the call time, not after. Fourth, check your insurance. General liability coverage that does not contemplate model health and safety on set is not enough anymore. Fifth, if you are paying models as freelancers, remember the Freelance Isn't Free Act runs alongside this law: contracts must outline the scope of work, payment terms, and the date of payment, and models must be paid within 30 days of service, regardless of whether the agency or client is issuing payment. Keep your deal memos, your consent forms, and your payment records in one place. The Department of Labor is actively enforcing this now, and "the agency handled it" is not a defense to your own obligations as a client.