AI content labeling

Must users label AI content they post themselves?

What you may need to do

1. Before publishing, check whether the platform has an AI content declaration entry point, and tick it truthfully if it does
2. For content whose metadata was lost in re-editing, add the declaration manually
3. If you need an original without an explicit label, apply through the agreed process and accept the labeling duty yourself
4. Keep the application record and the text of the agreement, so that you can explain the origin later

Clause basis

One-line answer

Where a user uses an online information content dissemination service to publish generated or synthesized content, the user shall declare it voluntarily and label it using the labeling function the service provider provides. In other words, it is not that the platform has to remind you first: the publisher has the duty to declare. If a user applies for content without an explicit label, Article 9 of the Measures allows the service provider to supply it after making the user's labeling duty and responsibility for use clear through the user agreement, provided that the relevant logs are kept as required by law for no less than six months.

The basis

Article 10: “Where a user uses an online information content dissemination service to publish generated or synthesized content, the user shall declare it voluntarily and label it using the labeling function provided by the service provider.”

Article 9: “Where a user applies to the service provider for generated or synthesized content without an explicit label added, the service provider may, after making the user's labeling duty and responsibility for use clear through the user agreement, provide generated or synthesized content that does not carry an explicit label, and shall keep logs of the recipient's information and other relevant records as required by law for no less than six months.”

What you need to do

Before publishing, check whether the platform has an AI content declaration switch, and tick it truthfully if it does — do not leave the default.

For content that has been edited, transcoded or subtitled, declare it again even if the original file carried a label, because metadata may be lost during processing.

If what you received is generated or synthesized content without an explicit label (internal material or a sample, for example), be clear that the labeling duty has shifted to you under the agreement, and that you must add the label yourself before it circulates publicly.

Keep the application record, the version of the agreement and the correspondence, so that you can explain the source if you are asked about it.

As an operator or an agency running accounts for others, write the declaration step into the publishing SOP and state who ticks the box and who checks it.

Common pitfalls

Assuming that “only I know AI wrote it” means no declaration is needed. Article 10 requires a voluntary declaration and does not make it conditional on whether anyone else knows.

Declaring the content but not using the platform's labeling function, or merely adding a line of text, without using the labeling function the service provider provides.

Circulating an unlabelled version publicly, in the mistaken belief that responsibility still sits with the service provider.

Handing the declaration step to an outsourced operator, so that the person responsible for the publishing account does not know whether a declaration was made.

Publishing the same material from different accounts and declaring it on only one of them.

Common follow-up questions

Q: What happens if a user does not declare?

A: Article 13 makes it clear that where these Measures are violated, the cyberspace, telecommunications, public security and radio and television departments and other relevant competent authorities shall handle the matter according to their duties and in line with the relevant laws, administrative regulations and departmental rules.

Q: The “no less than six months” in Article 9 — a deadline for what?

A: It is the period for which the service provider must keep logs of the recipient's information and other relevant records as required by law. It is not the validity period of the user's declaration.

Q: If an individual shares a picture they made with AI, do they have to declare it too?

A: Where an online information content dissemination service is used to publish generated or synthesized content, the article requires the user to declare it voluntarily and to use the labeling function the platform provides. We suggest following that.

Common follow-up questions

What if the platform provides no declaration entry point?

Article 6, item (4) requires dissemination platforms to provide the necessary labeling functions and to remind users to declare voluntarily. Where the platform does not provide one, you should still state the origin of the content as far as you can control it.

What are the conditions for obtaining an unlabelled version?

Article 9: the service provider may supply it after making the user's labeling duty and responsibility for use clear through the user agreement, and must keep the relevant logs as required by law for no less than six months.

This entry belongs to the “China AI Compliance and Filing” cluster (42 entries in total): View all · Answers home