On March 14, 2025, the Cyberspace Administration of China (CAC) released the final version of the “Measures for Labeling Artificial Intelligence-Generated Content,” along with the mandatory national standard GB 45438-2025, titled “Cybersecurity Technology – Labeling Method for Content Generated by Artificial Intelligence.” These regulations, collectively referred to as the “Labeling Rules,” are set to take effect on September 1, 2025.
Key Provisions of the Labeling Rules
The Labeling Rules impose explicit and implicit labeling obligations on “internet information service providers” and “providers of online content distribution services” that create AI-generated content. The rules implement labeling requirements established in China’s existing regulations on algorithmic recommendation, deep synthesis, and generative AI.
Explicit Labels: Content generated or synthesized using AI technologies—including text, images, audio, video, and virtual scenes—must include clear, visible indicators informing users that the content is AI-generated.
Implicit Labels: In addition to visible markers, AI-generated content files must contain embedded identifiers, such as digital watermarks or metadata tags, to indicate their synthetic nature.
Furthermore, when service providers offer functions like downloading, reproducing, or exporting AI-generated content, they must ensure that the files contain explicit labels that satisfy these requirements.
Implications for Global Companies
Companies operating in or targeting the Chinese market must assess their AI content generation and distribution practices to ensure compliance with these new regulations. This includes evaluating the technical capabilities to implement both explicit and implicit labeling mechanisms and updating content management systems accordingly.
Failure to comply with the Labeling Rules could result in regulatory penalties and impact a company’s ability to operate within China’s digital ecosystem.
Preparing for Compliance
To align with the upcoming requirements, companies should:
- Audit AI-Generated Content: Identify all content produced using AI technologies and assess current labeling practices.
- Implement Labeling Mechanisms: Develop or integrate tools that can apply both visible labels and embedded identifiers to AI-generated content.
- Update Policies and Procedures: Revise internal guidelines to reflect the new labeling obligations and ensure staff are trained on compliance measures.
- Monitor Regulatory Developments: Stay informed about any additional guidance or enforcement actions related to the Labeling Rules.
By proactively addressing these requirements, companies can mitigate compliance risks and demonstrate a commitment to transparency in AI-generated content.
For more detailed information on the Labeling Rules, refer to the official announcement by the Cyberspace Administration of China.
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