EveryAILaw.comDoes Measures for the Labeling of AI-Generated and Synthetic Content require Transparency & Disclosure?
China • enforcing
Yes — 1 provision
Requirements at a glance
This regulation imposes 11 specific requirements for Transparency & Disclosure across 1 provision:
- 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)
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 |