AI-generated content labeling

When listing on an app store, which labeling materials should you prepare?

What you may need to do

1. Prepare the statement materials: whether the app provides generated synthetic content services, and how and in what style it labels
2. Write the method and style of labeling into the user service agreement and prompt users to read it
3. Submit the labeling materials together with the algorithmic filing and security assessment
4. Re-align the listing materials whenever an AI feature is added or the app is revised

Statutory basis

One-sentence conclusion

An application distribution platform must, when an application is listed or reviewed for launch, require the application service provider to state whether it provides AI-generated synthetic content services; where it does, the distribution platform must verify the materials relating to the labeling of that content. Correspondingly, the service provider must explain the method and style of labeling in the user service agreement and prompt users to read it, and must supply the labeling materials under the Measures when handling algorithmic filing, security assessment and other procedures.

Basis

Article 7: “An internet application distribution platform shall, when an internet application is listed or reviewed for launch, require the internet application service provider to state whether it provides AI-generated synthetic content services. Where the internet application service provider provides AI-generated synthetic content services, the internet application distribution platform shall verify the materials relating to the labeling of that generated synthetic content.”

Article 8: “A service provider shall clearly explain in its user service agreement the method, style and other specifications of generated synthetic content labeling, and shall prompt users to read carefully and understand the relevant labeling management requirements.”

Article 12: “A service provider shall, when handling algorithmic filing, security assessment and other procedures, provide the materials relating to the labeling of generated synthetic content in accordance with these Measures, strengthen the sharing of labeling information, and provide support and assistance for preventing and combating the relevant illegal and criminal activities.”

What you need to do

Prepare a statement that can be checked: whether this application provides generated synthetic content services, the form of the service, the labeling method (explicit or implicit), and screenshots or descriptions of the label style and where it appears.

Write the labeling method and style into the user service agreement and set a reading prompt; do not settle for a single line about complying with the relevant laws and regulations.

When handling algorithmic filing, security assessment and other procedures, submit the labeling materials as an attachment and keep them consistent with what was given at listing.

When an app update adds an AI feature, or switches to calling a third-party model, run the statement and verification process again.

Keep the versions of everything submitted so that they can be retrieved quickly if a channel asks.

Common pitfalls

Explaining things orally in a channel group chat, with nothing in writing that can be verified.

A revised app that adds an AI generation feature without restating anything to the distribution platform — a typical omission.

A user agreement that describes the user experience rather than the method and style of labeling, which does not satisfy Article 8.

Filing and security assessment materials that do not match the actual product, leaving two competing positions in existence.

Treating the distribution platform’s verification as a formality and not maintaining the materials after delivery.

Follow-up questions

Q: If the app merely calls an external large model API, does it count as providing AI-generated synthetic content services?

A: The test is whether generated synthetic content services are provided; whether the model was trained in-house is not the only criterion, and using a third party does not change the nature of providing a service to users. The specific determination can be made together with the cyberspace administration authority for your locality.

Q: The distribution platform is asking for materials — what should I hand over?

A: Materials that can show how labeling is implemented, what it looks like and how it can be verified, consistent with Articles 7, 8 and 12.

Q: Filing and listing are two different things — can the materials be reused?

A: The position should stay consistent; the content can be reused, but it is better to organise it separately for each requirement so that contradictory descriptions do not appear.

Follow-up questions

Does an app with no AI features also have to make a statement?

Article 7 turns on the distribution platform having to require the application service provider to state whether it provides AI-generated synthetic content services; the statement itself is the required action.

What counts as adequate in a user agreement?

Article 8 requires the method, style and other specifications of labeling to be clearly explained, with a prompt for users to read carefully and understand the labeling management requirements.

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