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What a VFX change review record should establish
The record should let another reviewer determine what was submitted, what changed, what the AI contributed, and who approved or requested further work. UK Home Office engineering guidance says AI-assisted outputs should receive approval from suitably qualified, experienced people before production and that the organization retains accountability. Its guidance concerns engineering, not VFX, so human approval is best treated here as a sound review principle rather than an industry-wide VFX rule. The Home Office puts the principle this way: “AI tools cannot replace human judgement, understanding, ownership, or responsibility for decisions, designs, or changes made to systems.” UK Home Office engineering guidance.
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Human Provenance in Film (HPF) offers a useful example of version-specific provenance fields for film and television, but it does not publish a VFX-specific contract template. Its declaration is not an audit, rights clearance, consent record, or determination of legal or contractual compliance. A complete review record can establish that a review happened; it cannot, by itself, establish that every assertion is accurate or that the use is authorized. HPF and its workflow guidance make that distinction explicit.
Fields to include in the contract or review form
The fields below are a practical checklist derived from human-approval and provenance guidance. They are not a quoted standard or a ready-to-sign legal clause.
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1. Production, parties, and decision authority
- Production or project name and the relevant delivery, work order, or sequence.
- Submitting party, receiving organization, responsible vendor, and submission date.
- Name and role of the human reviewer, plus the person or organization authorized to approve the change.
- Whether approval requires one party’s signoff or a documented decision from both parties.
2. Exact version and scope
- Cut, sequence, or delivery version and the exact submission identifier.
- Affected shot, asset, or sequence IDs; include frame ranges where they help isolate the change.
- The current source version and submitted version, and a concise description of the proposed change.
- The specific output covered by the decision. Avoid treating a project name or a broad delivery label as proof that every shot was reviewed.
3. Factual AI-use description
- Tool or service, if known, and the function actually used—not merely a product or feature name.
- What human-created material was supplied, what the system changed, reconstructed, removed, or added, and where the result appears in the submitted VFX.
- Whether the system processed or reconstructed supplied material, originated content not present in the input, or did both.
- Any unknowns, supplier qualifications, or disputed descriptions, with the person responsible for resolving them.
HPF’s taxonomy distinguishes assistive processing of supplied human-created content from generative creation of content that was not supplied, but a tool can perform different functions in different uses. Describe the operation and resulting image or frames rather than inferring a category from a vendor’s label. HPF’s classification guidance says, “Unknown is never No AI Used”: missing information should remain unresolved until checked, not be converted into a clean declaration.
4. Evidence and acceptance criteria
- Identify or attach the relevant source/reference plates or assets where permitted, before-and-after frames, review movie, and comparison notes.
- Use stable links or identifiers that point to the exact submission and evidence set.
- State retention and access arrangements under the parties’ existing security rules; the cited guidance does not prescribe a VFX evidence-retention period.
- Set acceptance criteria before review: for example, visible quality, continuity, composition, technical delivery, creative intent, and project-specific constraints.
These criteria are practical recommendations, not thresholds supplied by HPF or the Home Office. Their value is that they make the approval basis explicit instead of leaving a later dispute to hinge on what someone meant by “looks good.”
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5. Findings, outcome, and corrections
- Record the decision as approved, approved with conditions, rejected/requested changes, or unresolved.
- Include the reviewer’s name and role, decision date and time, rationale, and specific required corrections or conditions.
- Identify who resolves conflicting accounts about AI use or source materials, and what must be established before approval or final classification.
- Specify how corrected records are issued and who receives them if a declaration or description proves inaccurate.
HPF says a declaration applies to the version it identifies; a changed or inaccurate version may need an updated declaration. The review terms should therefore say which later changes reopen review and require refreshed evidence—for example, a change to the AI output, the reviewed scope, or an agreed acceptance criterion. They should also define who receives the revised record. HPF’s workflow guidance describes its process as “a completeness check, not an audit.”
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HPF uses three top-level categories: No AI Used, Assistive AI, and Generative AI. Its system is a useful provenance example, not a universal VFX mandate. For the assistive/generative distinction, ask whether AI worked from supplied human-created material or originated/fabricated new content. If both kinds of use occur in the finished work, describe both; HPF says the highest applicable category governs.
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| Operation in the submitted VFX | What the review record should describe |
|---|---|
| Cleanup, restoration, or repair of supplied material | Identify the supplied plate or asset, the operation performed, and the resulting change visible in the submission. |
| New background or visual detail not present in supplied material | Identify what was originated, where it appears, and how it relates to any supplied material. |
| A system that generates pixels, frames, or audio while operating on existing human-created material | Record both the supplied input and the generated or reconstructed output; do not assume the feature name settles the category. |
| Unclear or incomplete supplier information | Mark the facts unresolved, name who must follow up, and avoid recording “No AI Used” until the question is answered. |
HPF’s September 2026 consultation update notes that the boundary can be difficult, particularly when a system generates pixels, frames, or audio while working on existing human material. Its v0.9.2 was a consultation draft, with consultation stated to close on 31 October 2026. The draft adds provisional descriptors without changing the three top-level categories and says there is no quantity threshold when qualifying AI-generated content appears in the finished production. Because this is consultation-stage guidance, check the published version before applying it later: HPF’s September 2026 update.
Keep review approval separate from rights, consent, and compliance
A VFX review signature should not imply that source material, likeness or voice use, confidentiality, data handling, union or collective terms, or legal compliance have been cleared. Route those questions through the applicable agreements and policies. HPF explicitly limits what its provenance declaration establishes; neither a declaration nor a creative/technical approval is a substitute for the relevant permission or legal analysis.
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There is also no basis for saying that every AI-assisted VFX change must be publicly labeled under the EU AI Act. The European Commission says Article 50 transparency obligations apply from 2 August 2026 and describes provider duties concerning machine-readable marking and detection of generated or manipulated outputs, alongside deployer disclosure duties for specified deepfakes and certain public-interest text. It also says the code of practice is voluntary even though Article 50 obligations are legal requirements. Whether a particular VFX change falls within an obligation depends on the facts and jurisdiction; the Commission’s overview is at AI-generated content: guidelines and code of practice.
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Contract terms can use different levels of detail, but the choice should be explicit. A single-shot review offers a narrow, traceable decision; a delivery-batch or version-wide review is broader and needs a reliable way to identify included shots and exceptions. A factual summary is lighter than a per-shot record with before-and-after evidence. A vendor self-check, qualified internal approval, client approval, or two-party signoff also represent different allocations of decision authority. Finally, a completeness check is not the same assurance as a substantive creative/technical review or a separate audit. HPF explicitly distinguishes its completeness check from an audit; contract language should not suggest a stronger assurance than the process actually provides.
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