ElevenLabs Routes Image and Video to Outside Models, and Disclaims What They Do

ElevenLabs keeps discretion over which vendors run underneath Image and Video; the customer absorbs the compliance and liability for them.

ElevenLabs is known for voice. Image & Video is a newer, secondary product, and because the company does not build its own image or video models, it runs on outside vendors. That part is expected. What changed on June 11, 2026 is the terms. ElevenLabs now has you represent and warrant that your inputs comply with those vendors’ requirements, reserves the right to add, remove, or replace the vendors at any time, and disclaims liability for anything they do. The terms name none of them. They appear on a separate subprocessor page, and two are companies this newsletter already tracks: Runway and Kling.

In human terms: A post house runs a client’s unreleased footage through Image & Video to generate a few shots. Under the new terms, that footage may be processed by any of six outside vendors, in locations that include the United States, Singapore, the European Union, Indonesia, and Malaysia. The post house cannot tell the client which vendor handled the material, and ElevenLabs can change the vendor without notice. If that vendor suffers a security incident, ElevenLabs disclaims liability for it. And by submitting the footage, the post house has already promised ElevenLabs that the material complies with that vendor’s requirements, which the terms do not disclose. The practical bite lands at the next client security review: the studio can no longer answer a standard data-handling questionnaire cleanly, because it cannot name where the footage was processed, commit to a data-residency region, or confirm which vendors touched it. More below:

Why this matters: The governance change is the part to mark. ElevenLabs has folded outside vendors’ requirements into the rules a user must follow, and changed the user’s position from agreeing to comply with those rules to warranting that its inputs do. Those vendors, and the requirements they set, can change independently of ElevenLabs. The providers’ rules now sit inside the contract the user warrants against, and the platform has stepped back from standing behind them. ElevenLabs has not yet made this change to its other service-specific terms, such as Studio and Agents, which still describe model providers in the older language. Image & Video is where the new approach appears first.

The mechanics. The Image & Video Terms moved from a 10 April 2026 version to an 11 June 2026 version. The substantive changes: • The providers became plural, and the routing became automatic. Prior (Section 1): “By using the Image & Video Services, you acknowledge and agree that you may interact with and direct information to these Third-Party Providers and that you must comply with any and all applicable Third-Party Provider terms or policies.” Updated (Section 1): “By using Image & Video, you acknowledge and agree that information submitted to the Services may be processed by Third-Party Providers as necessary to provide the functionality of Image & Video.” The prior version had you direct information to providers. The new version has information you submit processed by them as a normal part of running the feature. • ElevenLabs reserves the right to swap providers. Updated (Section 1, added): “ElevenLabs may add, remove, or replace Third-Party Providers at any time in its sole discretion.” This is a reserved right, so the subprocessor roster is a snapshot rather than a commitment. • A compliance obligation became a warranty. Prior (Section 1): “…you must comply with any and all applicable Third-Party Provider terms or policies.” Updated (Section 1): “You represent and warrant that you will not submit any Input that is prohibited under these Service Terms, the Prohibited Use Policy, applicable law, or applicable Third-Party Provider requirements.” A representation and warranty is a stronger commitment than a duty to comply, and here it covers the requirements of providers the terms do not name. • A new liability exclusion covers the providers. Updated (Section 6, added): “To the maximum extent permitted by law, ElevenLabs shall have no liability arising from or relating to any Third-Party Provider, including any act, omission, outage, interruption, delay, degradation, suspension, discontinuation, security incident, policy change, legal violation, or Output generated or provided by such Third-Party Provider.” Section 6 already excluded ElevenLabs’ intellectual property indemnity for Image & Video. This adds a second exclusion for the providers, reaching both a security incident affecting the inputs you sent them and the Output they return. • The prohibited-data restriction broadened. Prior (Section 3): “…bulk sensitive personal data relating to U.S. persons (including biometric identifiers)…” Updated (Section 3): “…sensitive personal data, restricted data, or other information prohibited by applicable law, regulation, governmental order, ElevenLabs policies, or applicable Third-Party Provider requirements, including biometric identifiers, government-issued identifiers, financial information, health information, precise geolocation data, or other sensitive personal data relating to US persons…” The word bulk is gone, so any quantity now applies. The list now includes government identifiers, financial information, health information, and precise geolocation, and the United States limit attaches only to the final catch-all. • A new Avatars section was added. Updated (Section 7, added): ““Avatars” are digital representations of humans or animated characters made available through the Services. Avatars include: (i) “Stock Avatars,” which are made generally available by ElevenLabs through the Services; and (ii) “Custom Avatars,” which are Output generated from your Input.”

The section sets terms for Stock Avatars only: you may not use them on a standalone basis outside the Services, and ElevenLabs reserves the right to modify, suspend, remove, or discontinue any Stock Avatar at any time without notice. Custom Avatars, the likenesses generated from your own input, are defined and otherwise left as ordinary Output, which carries the same no-indemnity treatment and, if shared, the sharing license below.

• What did not change: the sharing license. The Shared Output license in Section 2 is identical to the prior version. If you choose to share Output publicly, ElevenLabs receives a “worldwide, royalty-free, fully paid-up, transferable, and sublicensable (through multiple tiers)” license, and the opt-out applies only going forward. The new provider changes sit on top of a sharing license that was already broad.

• Who the providers are. The terms name no provider. The ElevenLabs subprocessor list, at https://compliance.elevenlabs.io/subprocessors, identifies the media-generation vendors.

Matching a given vendor to Image & Video is read from these service descriptions; the list does not map vendors to features, and the terms reserve the right to change the roster. The list as captured for this issue is current as of publication.