facial recognition is already embedded across modern travel, from biometric boarding gates to keyless hotel check-ins, and Denmark is proposing a legal shift that could change how that technology is governed. the draft Danish law would grant individuals copyright-like control over their likeness—their face, voice and body—as captured in photographs, video, voice recordings or Artificial Intelligence-generated content such as deepfakes and avatars. the proposal would allow people to demand removal of unauthorised representations and to seek compensation for misuse, and it would expose hosting platforms to fines if they fail to act. satire and parody are explicitly protected in the draft, but the scope of those exceptions will likely be litigated. Denmark’s intention to assume the EU presidency increases the potential that this model could influence EU-wide reform.
the implications for travel operators are practical and immediate. airlines, airports and hospitality providers that deploy biometric systems could face claims not only under data protection regimes but also under a copyright-like framework for likeness ownership. scenarios flagged in the proposal include reuse of a passenger’s facial scan in promotional materials without explicit permission, hotels objecting guests to how their likeness is stored or shared, and cruise lines that create AI-driven avatars from passenger photos. each of these practices could trigger demands for removal, compensation and legal challenges, changing vendor liability, consent requirements and content reuse policies across the sector.
the Danish initiative arrives alongside tightening regulation elsewhere. the EU Artificial Intelligence Act, adopted in March 2024, classifies biometric systems as high-risk and includes measures such as a prohibition on real-time facial recognition in public areas, mandatory human oversight and risk assessments, extraterritorial reach and fines up to €35 million or 7% of global turnover. in the UK there is no single statutory Artificial Intelligence law, but GDPR and the Information Commissioner’s Office guidance apply; the ICO clarified on 13 August 2025 that data protection law governs facial recognition use, particularly by police. with the UK Border Force planning contactless facial entry by 2026, travel companies are advised to audit biometric systems, review vendor contracts, update consent mechanisms and monitor cross-border legal change. hill dickinson offers regulatory, contractual and incident-response support and names Ezequiel T. Condoluci Santa Maria as a contact for further assistance.
