On 14 March 2025, China released the Measures for the Labelling of Artificial Intelligence-Generated and Synthetic Content (Measures), a regulatory framework aimed at standardising labelling requirements for AI-generated content. The Measures were jointly issued by the Cyberspace Administration of China, the Ministry of Industry and Information Technology, the Ministry of Public Security, and the National Radio and Television Administration. Following the release of a draft in September 2024, the finalised Measures are set to take effect on 1 September 2025.
Introduction
The new measures introduced by China provide the standard requirements to be followed by the providers of generation and synthesis services. The measures mandate the providers to add explicit and implicit labels (as applicable) to generated synthetic content, including texts, images, audios, videos and virtual scenes. The measures are followed by the earlier released Cybersecurity Standard Practice Guide – Generative Artificial Intelligence Service Content Identification Method, issued in August 2023 by the National Information Security Standardisation Technical Committee (TC260), which laid the groundwork for identifying AI-generated content.
Applicability of the Measures
The Measures target internet-based information service providers engaged in AI-generated content labelling. The measures are specifically applied to providers already required to comply with the earlier regulations:
- Administrative Provisions on Recommendation Algorithms in Internet-based Information Services (Recommendation Algorithms Provisions) – Regulating the use of algorithm technologies for content recommendations.
- Administrative Provisions on Deep Synthesis in Internet-based Information Services (Deep Synthesis Provisions) – Addressing the use of deep synthesis technologies in online services.
- Interim Measures for the Management of Generative Artificial Intelligence Services (GenAI Measures) – Governing the use of AI to generate texts, images, audios, and videos.
Explicit and Implicit Labelling Requirements
Under the Measures, service providers must implement explicit and implicit labels to distinguish AI-generated content.
“Explicit Labels: Service providers are required to add clear labels (such as text and voice prompts and visual symbols) to AI-generated content that is considered high-risk in causing confusion or misrecognition among the public under the Deep Synthesis Provisions (such as smart dialogue, voice synthesis and face generation services),” the document states.
Explicit labelling methods vary based on content type:
- Text – Text prompts or symbols at the start, end, or within the content.
- Audio – Audio prompts at the beginning, end, or within the audio file.
- Images – Visible signs in appropriate positions.
- Videos – Identifiers at the start, end, or around the video.
- Virtual Scenes – Identifiers at the start and during the service process.
- Other Scenarios – Unique prominent signs tailored to the specific context.
Furthermore, “Implicit Labels: Service providers must embed implicit labels in the metadata of the generated content, which should include information such as content attributes, provider name, and content number.”
Verification and Compliance Measures
To ensure compliance, providers of content dissemination services must verify the presence of implicit labels and add explicit ones where necessary. “Verification Measures: Providers of content dissemination services must verify the presence of implicit labels (such as by checking the metadata of documents) and add explicit labels if the content is identified as AI-generated.”
Additionally, service providers must revise user agreements to clarify labelling obligations. “User Agreements: Service providers must clearly outline labelling methods and requirements in user service agreements to ensure that users understand their obligations regarding content labelling. The Measures also permit a user to request a service provider to provide generated and synthetic content without explicit labels, and the service provider is permitted to do so provided that it has clarified the user’s obligations in the user agreement and retains relevant logs for not less than 6 months.”
Implications for Businesses
Businesses that provide AI generation or synthesis services are expected to review their current technical and legal frameworks to ensure compliance before the Measures take effect. As the next steps, businesses providing AI generation or synthesis services should review their existing technical setup and the relevant user terms and conditions or agreements and update internal policies to ensure compliance before the lapse of the transitional period.
China’s Expanding AI Regulatory Landscape
As the Chinese government announced in July 2024 that the country is looking to formulate over 50 standards for the AI sector by 2026, it is important to monitor further development of laws and standards related to internet information services and AI technology in China. With the AI industry evolving rapidly, legal and regulatory shifts in China are expected to have significant consequences for both domestic and international technology firms. As China advances its AI governance framework, global businesses operating in the region must stay informed and adapt to ensure regulatory compliance in the evolving landscape.
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