Obligations and Interlinkages under the Measures for Labeling AI-Generated Content

In March 2025, the Cyberspace Administration of China (CAC), the Ministry of Industry and Information Technology, the Ministry of Public Security, and the National Radio and Television Administration jointly issued the Measures for Labeling Artificial Intelligence-Generated and Synthesized Content (Guoxinbantongzi 〔2025〕 No. 2). The Measures took effect on September 1, 2025, and the supporting mandatory national standard GB 45438-2025 took effect on the same day. The Measures consist of fourteen articles. They set out rules for explicit and implicit labels on generated and synthesized content. They also extend verification, notification, and declaration obligations to content dissemination platforms, app distribution platforms, and users who publish content.

Scope of Application and Nature of the Document

Article Two of the Measures limits their application to “network information service providers falling under the circumstances specified in the Provisions on the Administration of Algorithmic Recommendations for Internet Information Services, the Provisions on the Administration of Deep Synthesis of Internet Information Services, and the Interim Measures for the Administration of Generative Artificial Intelligence Services.” The Measures do not create a separate definition of covered entities. Instead, they adopt the service types already defined by these three departmental rules. Article Three defines “AI-generated and synthesized content” as text, images, audio, video, virtual scenes, and other information generated or synthesized using artificial intelligence technology.

The Measures were issued as a notice dated March 7, 2025, and were published on China Cyberspace, the CAC website, on March 14. In a Q&A with reporters, a CAC official described them as a “normative document” that refines the labeling requirements already contained in the three rules above. The Q&A also states that where other provisions govern news publishing, film and television production, literary and artistic creation, or similar activities, “those provisions shall apply.” The Measures work together with the mandatory national standard Cybersecurity Technology — Labeling Method for Artificial Intelligence-Generated and Synthesized Content (GB 45438-2025, released February 28, 2025). The Measures set out the responsibilities and obligations of each party. The standard specifies concrete labeling methods, such as text, corner marks, voice, rhythm, and metadata. According to the Q&A, the two documents provide a transition period of about 6 months and both took effect on September 1, 2025.

Explicit and Implicit Labels

Article Three distinguishes two types of labels. Explicit labels are presented in the content or in the interface of an interactive setting through text, sound, graphics, or other means, and users can clearly perceive them. Implicit labels are added to file data through technical measures, and users cannot easily perceive them.

Explicit labeling (Article Four) applies to the services covered by the first paragraph of Article Seventeen of the Deep Synthesis Provisions. These are services that may cause public confusion or misidentification, such as intelligent dialogue and intelligent writing, synthetic human voices and voice imitation, face generation and swapping, and immersive realistic scenes. The Measures set placement requirements for each medium:

• Text: a text prompt or a general symbol prompt at the beginning, at the end, or at an appropriate position in the middle.
• Audio: a voice prompt or an audio rhythm prompt.
• Images: a prominent prompt at an appropriate position.
• Video: prompts on the opening frame and around the playback area.
• Virtual scenes: a prompt on the opening frame.

Where a service offers download, copy, or export functions, the exported files must also contain explicit labels that meet these requirements.

Implicit labeling (Article Five) applies to all service providers covered by the Measures, not only to the services in the first paragraph of Article Seventeen. Under Article Sixteen of the Deep Synthesis Provisions, providers must add “production element information” to file metadata. This includes attribute information identifying the content as generated or synthesized, the service provider's name or code, and a content number. Digital watermarks are “encouraged” rather than mandatory. The Q&A explains why: adding implicit labels to text and adding digital watermarks to multimedia files still pose technical difficulties or may increase costs for companies, so neither is made mandatory.

Obligations of Platforms, Providers, and Users

Article Six sets out most of the obligations at the dissemination stage. Platforms that provide network information content dissemination services must first check file metadata for implicit labels. They must then add a prompt around the published content based on which of three situations applies:

• Metadata identifies the content: if the metadata clearly identifies the content as generated or synthesized, the platform tells the public that the content “is” generated or synthesized.
• The user declares the content: if the platform finds no implicit label but the user declares the content as generated or synthesized, the platform tells the public that the content “may be” generated or synthesized.
• The platform detects traces: if there is neither an implicit label nor a user declaration, but the platform detects explicit labels or other traces of generation or synthesis, the platform identifies the content as “suspected” generated or synthesized content.

In all three situations, the platform must also write “dissemination element information” into the metadata, such as the dissemination platform's name or code and a content number. In addition, platforms must provide labeling functions and remind users to declare on their own initiative whether the content they publish contains generated or synthesized content.

The obligations of other parties appear in later articles. When reviewing an app for listing or launch, an app distribution platform must require the app to state whether it provides generation or synthesis services. If it does, the platform must verify its labeling-related materials (Article Seven). Service providers must explain their labeling methods and styles in their user service agreements (Article Eight). They must also submit labeling-related materials when completing procedures such as algorithm filing and security assessments (Article Twelve). If a user asks for content without explicit labels, the provider may supply it after setting out the user's labeling obligations and usage responsibilities in the user agreement. In that case, the provider must retain logs, including information on the recipient, for no less than six months as required by law (Article Nine).

On the user side, Article Ten requires users who publish generated or synthesized content through network information content dissemination services to declare it on their own initiative and to use the labeling functions provided by the platform. The second paragraph of the same article sets out prohibitions that apply to “any organization or individual.” No one may maliciously delete, tamper with, forge, or conceal labels. No one may provide tools or services that help others do so. No one may use improper labeling methods to harm the lawful rights and interests of others. Based on these provisions, the Q&A explains that if a user obtains content without explicit labels from a provider, the user must still declare the content and add explicit labels before publishing it to the public.

On liability, Article Thirteen provides that violations of the Measures are handled by the competent cyberspace, telecommunications, public security, and radio and television authorities, each within its own remit, under the relevant laws, administrative regulations, and departmental rules. The Measures themselves do not set out any separate penalties.

Linkages with Two Departmental Rules

The Measures cite the Provisions on the Administration of Deep Synthesis of Internet Information Services more directly than any other higher-level rule. These Provisions are Order No. 12 of the CAC, the Ministry of Industry and Information Technology, and the Ministry of Public Security, and took effect on January 10, 2023. Their Article Sixteen requires providers to “take technical measures to add labels that do not affect users' use” to content they generate or edit. Article Five of the Measures turns this into a specific requirement for implicit labels in metadata and lists the information those labels must contain. Article Seventeen of the Provisions requires services that may cause public confusion or misidentification to be “prominently labeled.” Article Four of the Measures specifies where explicit labels must be placed for text, audio, images, video, and virtual scenes. Article Eighteen of the Deep Synthesis Provisions prohibits using technical means to “delete, tamper with, or conceal” labels. Article Ten of the Measures builds on this by adding “forge” to the list. It also prohibits providing tools or services that help others commit these acts and using improper labeling methods to harm others' rights and interests. Article Thirteen of the Deep Synthesis Provisions already requires app distribution platforms to verify the security assessments and filing status of deep synthesis apps. Article Seven of the Measures extends this verification to labeling-related materials.

The Interim Measures for the Administration of Generative Artificial Intelligence Services are Order No. 15 of seven departments, including the CAC, and took effect on August 15, 2023. They address labeling in only one sentence, in Article Twelve: providers shall “label generated content such as images and videos” in accordance with the Deep Synthesis Provisions. The labeling Measures expressly list text, images, audio, video, virtual scenes, and similar content as objects of labeling. They also add requirements for the dissemination stage that earlier provisions did not spell out. These include verification and tiered prompts by content dissemination platforms and declarations that users must make on their own initiative. Article Seventeen of the Interim Measures provides for algorithm filing and security assessment procedures. Through Article Twelve of the labeling Measures, these procedures are now linked to the submission of labeling materials.

References

1. Cyberspace Administration of China, Ministry of Industry and Information Technology, Ministry of Public Security, and National Radio and Television Administration: Notice on Issuing the Measures for Labeling Artificial Intelligence-Generated and Synthesized Content (Guoxinbantongzi 〔2025〕 No. 2), China Cyberspace, March 14, 2025.

2. Official of the Cyberspace Administration of China: Q&A with Reporters on the Measures for Labeling Artificial Intelligence-Generated and Synthesized Content, China Cyberspace, March 14, 2025.

3. Cyberspace Administration of China, Ministry of Industry and Information Technology, and Ministry of Public Security: Provisions on the Administration of Deep Synthesis of Internet Information Services (Order No. 12), China Cyberspace, December 11, 2022.

4. Cyberspace Administration of China and six other departments: Interim Measures for the Administration of Generative Artificial Intelligence Services (Order No. 15), China Cyberspace, July 13, 2023.

5. State Administration for Market Regulation and Standardization Administration of China: GB 45438-2025 Cybersecurity Technology — Labeling Method for Artificial Intelligence-Generated and Synthesized Content, National Standards Full-Text Public System, released February 28, 2025, effective September 1, 2025.

6. Xishu Zhifa · Law is the art of the rules of the game

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