ElevenLabs Routes Image and Video to Outside Models, and Disclaims What They Do | The Ledger The Ledger /<br>Vol 26, No 16 / the-notice

ELEVENLABS TERMS OF SERVICE DATA_SHARING DELEGATED_GOVERNANCE DATA_RESIDENCY THIRD_PARTY_PROVIDERS CONTENT_OWNERSHIP<br>ElevenLabs Routes Image and Video to Outside Models, and Disclaims What They Do<br>A Big One

ElevenLabs<br>— Terms of Service - Image and Video<br>ElevenLabs keeps discretion over which vendors run underneath Image and Video; the customer absorbs the compliance and liability for them.<br>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.<br>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:<br>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.<br>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...