EveryAILaw.comMeasures for the Labeling of AI-Generated and Synthetic Content
Obligations Covered
Timeline
| Milestone | Date | Notes |
|---|---|---|
| Signed | Mar 7, 2025 | Date borne by the Measures themselves, over the four issuing bodies' seals |
| Published | Mar 14, 2025 | Circulated as 国信办通字〔2025〕2号 by CAC, MIIT, MPS and NRTA |
| Effective | Sep 1, 2025 | Article 14; mandatory national standard GB 45438-2025 applies from the same date |
Related Regulations and Standards
Related instruments are selected from shared compliance obligations and jurisdiction coverage.
AI Content Labeling Disclosure
Article 4 requires explicit labels for generative and deep-synthesis services within the specified Deep Synthesis Provisions Article 17(1) scenarios. Article 9 permits delivery without an explicit label on user request if the provider allocates labeling duties and use responsibilities in the user agreement and retains recipient information and related logs for at least six months. Article 10 extends the anti-tampering prohibition to **any organization or individual**, including providers of label-removal tools or services.
Requirements
| Requirement | Details |
|---|---|
| Text explicit label | Add a textual or common-symbol prompt at the start, end, or an appropriate interior position of the text, or a conspicuous prompt in the interaction interface or around the text (Article 4(1)) |
| Audio explicit label | Add a voice or rhythm-cue prompt at the start, end, or an appropriate interior position of the audio, or a conspicuous prompt in the interaction interface (Article 4(2)) |
| Image explicit label | Add a conspicuous prompt label at an appropriate position in the image (Article 4(3)) |
| Video explicit label | Add a conspicuous prompt at the opening frame and around the playback area; optionally also at the end and at appropriate interior positions (Article 4(4)) |
| Virtual scene explicit label | Add a conspicuous prompt at an appropriate position in the opening frame; optionally also at appropriate points during continuing service (Article 4(5)) |
| Label survives export | When offering download, copy, or export, ensure the resulting file still carries a conforming explicit label (Article 4, second paragraph) |
| User-requested unmarked delivery | A provider may supply generated content without an explicit label on user request after specifying the user's labeling obligations and use responsibilities in the user agreement; retain recipient information and related logs for at least six months (Article 9) |
| Service agreement disclosure | State the labeling methods and styles in the user service agreement and prompt users to read and understand the labeling requirements (Article 8) |
| User declaration duty | Users publishing generated content through a dissemination service must proactively declare it and use the labeling function the provider supplies (Article 10, first paragraph) |
| Anti-tampering prohibition | No organization or individual may maliciously delete, alter, forge, or conceal a label, provide tools or services for others to do so, or harm others' lawful rights through improper labeling (Article 10, second paragraph) |
| Standards conformity | Labeling activity must also satisfy applicable laws, administrative regulations, departmental rules, and mandatory national standards — in practice GB 45438-2025 (Article 11) |
Penalties
| Violation | Fine |
|---|---|
| Any violation of the Measures |
Implicit Metadata Labels and Provenance Records
Article 5 specifies the implicit metadata elements for covered generated content under Article 16 of the Deep Synthesis Provisions: content attribute information, provider name or code, and content number. Article 9 permits delivery without an explicit label on user request after the user agreement allocates labeling and use responsibilities; the provider must retain recipient information and related logs for at least six months.
Requirements
| Requirement | Details |
|---|---|
| Implicit metadata label | Add an implicit label to the file metadata of generated content as required by Article 16 of the Deep Synthesis Provisions, containing content attribute information, the provider's name or code, and a content number (Article 5, first paragraph) |
| Digital watermarking | Providers are encouraged, not required, to add implicit labels in the form of digital watermarks (Article 5, second paragraph) |
| Dissemination metadata | Where a dissemination platform applies a prompt label under Article 6(1)-(3), it must also write content attribute information, the platform name or code, and a content number into the file metadata (Article 6, second paragraph) |
| Delivery without an explicit label | On user request, a provider may deliver generated content without an explicit label after the user agreement specifies the user's labeling obligations and use responsibilities; retain recipient information and related logs for **not less than six months** (Article 9) |
| Filing materials | Submit labeling materials when completing algorithm filing and security assessment formalities, and strengthen sharing of labeling information to support the prevention and investigation of related offences (Article 12) |
Penalties
| Violation | Fine |
|---|---|
| Any violation of the Measures |
Platform Label Verification
The compliance dimension the Deep Synthesis Provisions do not have: duties that bind actors who never generated the content. Article 6 makes every covered network-information-content dissemination-service provider a verifier with a three-tier response, and Article 7 adds an app-store listing check.
Requirements
| Requirement | Details |
|---|---|
| Verify metadata | Dissemination platforms must check whether file metadata contains an implicit label; where the metadata clearly marks content as generated, add a conspicuous prompt around the published content stating plainly that it is generated content (Article 6(1)) |
| Handle user declarations | Where no implicit label is found but the user has declared the content as generated, add a conspicuous prompt stating the content **may be** generated (Article 6(2)) |
| Detect suspected content | Where there is neither an implicit label nor a user declaration, but the platform detects an explicit label or other traces of generation, classify it as **suspected** generated content and add a conspicuous prompt saying so (Article 6(3)) |
| Provide labeling function | Provide the necessary labeling function and prompt users to proactively declare whether published content contains generated content (Article 6(4)) |
| App store listing check | At listing or launch review, app distribution platforms must require the app provider to state whether it offers AI generation or synthesis services, and where it does, must verify the provider's content-labeling materials (Article 7) |
Penalties
| Violation | Fine |
|---|---|
| Any violation of the Measures |
Cite this regulation
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Attribution: EveryAILaw, PAICE.work PBC. “Measures for the Labeling of AI-Generated and Synthetic Content”, EveryAILaw.com, Aug 20, 2026. https://everyailaw.com/regulation/cn-ai-content-labeling/
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