Labeling of AI-generated and synthesized content

What happens if AI content is not labeled?

What you may need to do

1. Put labeling compliance on the pre-launch checklist; do not go live with a known defect
2. Map the other laws and mandatory national standards that apply instead of looking at these Measures alone
3. Name the person who answers inquiries from the cyberspace administration, telecommunications, public security and radio and television authorities
4. Keep labeling implementation notes, metadata field definitions and agreement texts on file for inspection

Provisions relied on

One-line conclusion

Violations of these Measures are handled by the competent cyberspace administration, telecommunications, public security, radio and television and other relevant authorities according to their duties and in accordance with the provisions of relevant laws, administrative regulations and departmental rules. The Measures do not create an independent fine tier; the basis for handling lies in existing laws and regulations. At the same time, carrying out labeling activities must also comply with the requirements of relevant laws, administrative regulations, departmental rules and mandatory national standards. These Measures took effect on September 1, 2025.

Basis

Article 13: “Violations of these Measures are handled by the competent cyberspace administration, telecommunications, public security, radio and television and other relevant authorities according to their duties and in accordance with the provisions of relevant laws, administrative regulations and departmental rules.”

Article 11: “Where a service provider carries out labeling activities, it shall also comply with the requirements of relevant laws, administrative regulations, departmental rules and mandatory national standards.”

Article 14: “These Measures shall take effect on September 1, 2025.”

What you need to do

Write labeling compliance into the pre-launch checklist: whether the explicit label is in place, whether the implicit label is written in, whether the user agreement explains it, and whether distribution and filing materials are complete.

Map the other applicable laws, administrative regulations, departmental rules and mandatory national standards (Article 11); do not remediate against these Measures alone.

Name the internal contacts: decide in advance who answers inquiries from the cyberspace administration, telecommunications, public security and radio and television authorities, so no one has to be found at the last minute.

Keep the evidence: labeling implementation notes, metadata field definitions, test records, agreement texts and the versions of the materials filed with app stores.

Watch the effective date: the Measures took effect on September 1, 2025, so legacy versions still in service belong in the review scope as well.

Common pitfalls

Assuming there is no cost because the Measures do not print a fine amount, and missing that Article 13 points to existing liability under other laws and regulations.

Implementing only the explicit label and omitting the implicit one — that is equally a failure to meet the requirement, and harder to catch in a self-check.

Misremembering the effective date and treating the transition period as a gap with no obligations.

Handling a problem internally without reporting or remediating it, then having no materials to show when a regulatory interview happens.

Pushing all responsibility onto the model provider and ignoring your own duties at your stage of the chain.

Frequently asked follow-ups

Q: Can several authorities regulate at the same time?

A: The provision lists the competent cyberspace administration, telecommunications, public security, radio and television and other relevant authorities, which handle matters according to their division of duties.

Q: How much will the fine actually be?

A: The Measures list no specific penalty amount. Article 13 says handling follows the provisions of relevant laws, administrative regulations and departmental rules, so the specific application depends on those laws and regulations.

Q: When do the Measures take effect?

A: Article 14 states that the Measures take effect on September 1, 2025.

Frequently asked follow-ups

Who enforces a violation?

Article 13: the competent cyberspace administration, telecommunications, public security, radio and television and other relevant authorities handle it according to their duties.

What other requirements must be met?

Article 11: carrying out labeling activities must also comply with the requirements of relevant laws, administrative regulations, departmental rules and mandatory national standards.

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