AI Imitation of (Dubbing) Voices and Personality Rights: What Is Protected under German Law?

Artificial intelligence (AI) now makes it possible to imitate voices in a deceptively realistic way – but anyone who uses the voice of prominent personalities without their consent commits a violation of personality rights under German Law. This was clarified by the Berlin District Court II in a landmark judgment dated August 20, 2025 (Case No. 2 O 202/24). A YouTuber who used AI to generate an imitation of German voice actor Manfred Lehmann’s distinctive dubbing voice must now pay 4,000 euros in notional licensing fees – a signal with far-reaching consequences, especially for voice actors.

The Case: When AI Imitates the Voice of a Legend

Manfred Lehmann is one of Germany’s most famous voice actors. Millions of film fans know his distinctive voice as the German voice of Bruce Willis or Gérard Depardieu. A YouTuber with approximately 190,000 subscribers took advantage of precisely this fame: He had AI software imitate Lehmann’s characteristic dubbing voice and used it to narrate two videos on his channel – without Lehmann’s knowledge or consent. Numerous viewers immediately identified Lehmann’s voice in the comments and assumed that the 80-year-old voice actor had narrated the videos. There was no indication whatsoever that the YouTuber used an AI-generated voice.

When Lehmann learned of the unauthorized use, he sent a cease-and-desist letter. Although the YouTuber issued a cease-and-desist declaration, he refused to pay a licensing fee and the legal costs. Lehmann then filed suit before the Berlin District Court II – successfully.

Legal Background: The Right to One’s Own Voice

Unlike the right to one’s own image, which is expressly regulated in Sections 22 et seq. of the German Art Copyright Act (KUG), there is no explicit provision in Germany for the protection of the voice. Nevertheless, it is recognized in case law and legal literature that the general right of personality under Article 1(1) of the German Basic Law (GG), in conjunction with Article 2(1) GG,is the right to one’s own voice.

The voice is considered an identifiable personality characteristic – comparable to a person’s name or likeness. Earlier court decisions, such as the Hamburg Higher Regional Court’s Decision of May 8, 1989 (Case No. 3 W 45/89), had already affirmed personality rights violations in cases involving voice imitations. The German Federal Court of Justice (BGH) has also clarified that personality rights protect not only non-material interests but also economic interests: the voice can have considerable economic value, over which only the rights holder may exercise control.

The Ruling

The Berlin District Court II established several fundamental points in its decision that are essential for future cases:

Risk of Confusion Through AI Voice Imitation

The court made clear: it is irrelevant whether a voice is used in the original, imitated by a human imitator, or generated by AI. What is decisive is the risk of confusion (“Zuordnungsverwirrung”) among the audience caused by the deliberate similarity. A significant portion of viewers assumed, based on the similarity, that Manfred Lehmann had narrated the videos, as the comments under the videos clearly demonstrated. The court also rejected the defendant’s argument that he had merely searched for an “authentic voice with a heroic sound.” Although the voice suggested by the system was an AI imitation and not “the” original voice of Lehmann, the legal situation should not be assessed differently from a human voice imitation.

Dubbing Voice Enjoys Independent Protection

Interestingly, the court clarified that not only a person’s “natural” everyday voice is protected, but also their professional dubbing voice. Lehmann’s characteristic dubbing voice, with which he speaks for Bruce Willis, is an independent, protectable personality characteristic – even if it differs from his normal speaking voice.

Commercial Use Outweighs Artistic Freedom

The defendant claimed that his videos were satirical in nature and covered by freedom of expression and artistic freedom. The court did not follow this argument. While the videos had satirical content, the use of Lehmann’s well-known voice primarily served commercial purposes: it was intended to make the videos more attractive, increase view counts, and ultimately promote the linked online shop. The satirical engagement with the government would have been possible for the YouTuber even without using Lehmann’s voice. Artistic freedom, therefore, did not justify the interference with Lehmann’s personality rights.

Reputational Risk Through Political Association

Another important aspect is that the use of the voice could lead viewers to think that Lehmann identified with the content of the “apparently politically rather right-leaning” YouTuber. This could negatively affect Lehmann’s reputation.

Lack of AI Labeling Aggravates the Rights Violation

The court expressly criticized the videos for containing no indication whatsoever that the voice was AI-generated. This lack of transparency further aggravated the assessment of the rights violation.

Notional Licensing Fee as Standard for Compensation

To determine damages, the court followed the Federal Court of Justice’s case law on unauthorized use of images for advertising purposes. Anyone who uses a third party’s personality characteristic without authorization for commercial purposes thereby demonstrates that they attribute economic value to it, and must pay appropriate compensation. The amount of the notional licensing fee was estimated in accordance with Section 287(2) of the German Code of Civil Procedure (ZPO). The decisive factor is what reasonable contracting parties would have agreed on for the specific use. The court set a notional licensing fee of 2,000 euros per video. With the two affected videos, this resulted in a total amount of 4,000 euros plus reimbursement of out-of-court legal costs.

Recommended Actions for Voice Actors and Voice Talents

In General | Conduct Regular Monitoring

• Actively monitor whether your voice is being used without your consent on platforms such as YouTube, TikTok, Instagram, or in podcasts.
• Tip: Use Google Alerts with your name and terms like “voice acting,” “voice,” or the names of actors you have dubbed.

In General | Adapt Contract Terms

• When entering into a contract or amending existing contracts: Include specific AI clauses, cloning prohibitions, definition of usage scope, and contractual penalties!

In Case of Suspicion | Secure Evidence Immediately

• Create screenshots and video recordings of the questionable content.
• Document URLs, upload dates, and channel/account information.
• Save user comments that identify your voice.
• Note view counts, reach, and commercial links (e.g. links to online shops).
• Store analytics data if available.

In Case of Suspicion | Obtain Initial Legal Assessment

• Contact us as soon as possible. We will examine whether cease-and-desist and/or compensation claims exist and provide comprehensive advice.

Conclusion: Voice as a Protectable Personality Characteristic – Even in Generated Form

The judgment of the Berlin Regional Court II marks a significant turning point in the handling of AI-generated voices. It demonstrates: the voice is a protectable personality characteristic with economic value, regardless of whether it is used in the original or as an AI imitation. Anyone who uses prominent or characteristic voices for commercial purposes without consent risks not only cease-and-desist claims but also substantial damage claims.