The Ministry of Labour conducted a public consultation period on the reform of the labour regime for artists and the use of generative AI

The Ministry of Labour and Social Economy opened the period for submitting comments on the draft Royal Decree that redefines the employment regime for artists, technical staff, and assistants in the performing, audiovisual, and musical arts, which incorporates specific regulations on the use of artificial intelligence and new guarantees for minors. The deadline for submitting comments was 2nd February 2026.

Key points:

• Updated labour framework for the cultural sector: the proposed regulation replaces the previous regulation from 1985 and adapts the special employment relationship to the current reality of the sector, including phases such as preparation, shooting, post-production, and promotion, as well as activities conducted in digital environments and online platforms.
• Specific regime for minors working in artistic activities: the protection of minors participating in artistic projects has been consolidated, with limits on working hours based on age, reinforcing the prevention of risks and requiring that their activity is compatible with schooling and family and social life.
• Reinforced protection against harassment and sensitive content: the text of the Royal Decree requires specific measures against violence and harassment and imposes the obligation to have an intimacy coordinator for scenes of a sexual nature or particularly sensitive, with reinforced obligations for information and protection when minors are involved.
• Regulation of generative AI in artistic contracts: it was determined that the use of AI systems to generate content related to the image, voice, or performances of artists is not presumed to be included in the contract and can only be used in relation to the specific work for which they have been contracted, without substantially replacing them or creating situations of intensive imposition of their professional identity. When intending to go beyond these limited uses (for example, through digital replicas or new recognizable materials not directly linked to the agreed project), an additional written agreement and separate, clearly identifiable remuneration from other salary concepts will be required.

Access the full content:

• Official text: text RD.
• Report: report RD.