China Deep Synthesis Regulations

Deep Synthesis Provisions · Cyberspace Administration of China (CAC), Ministry of Industry and Information Technology (MIIT), Ministry of Public Security (MPS)

China's Provisions on the Administration of Deep Synthesis Internet Information Services regulate the development, distribution, and use of deep synthesis technologies-including AI-generated or AI-manipulated text, images, audio, video, and virtual humans-by service providers and users operating in or targeting China. They impose labelling, registration, security-assessment, and content-moderation obligations.

Overview

The Provisions on the Administration of Deep Synthesis Internet Information Services (《互联网信息服务深度合成管理规定》) were promulgated jointly by the Cyberspace Administration of China, the Ministry of Industry and Information Technology, and the Ministry of Public Security. They came into effect on 10 January 2023. The provisions define 'deep synthesis' broadly to encompass any technology that uses deep learning, virtual reality, or related techniques to generate or materially alter text, images, audio, video, virtual scenes, or virtual persons. This definition captures generative AI models, voice cloning, face swapping, lip-sync manipulation, text-to-image systems, AI-generated avatars, and similar capabilities. The regulations apply to deep synthesis service providers-entities that develop or operate platforms offering deep synthesis tools-and to deep synthesis users who deploy those tools to create or disseminate content. The framework sits within China's broader AI content governance architecture, which includes the Generative AI Measures (effective August 2023), the Algorithm Recommendation Provisions (effective March 2022), and the overarching Cybersecurity Law and Data Security Law. Enterprises with any deep synthesis product, feature, or workflow touching users in China-whether operating domestically or cross-border-must assess whether the provisions apply to their technical stack and content supply chain. Particular attention is required for enterprises using third-party AI-generated content APIs, synthetic media in advertising, AI avatars in customer service, and AI-generated dubbing or subtitling.

Key Requirements

•Deep synthesis service providers must implement real-name registration for users, verifying identity before permitting access to synthesis tools.
•Synthetic content that could cause public confusion must carry a visible and non-removable label disclosing its AI-generated or AI-modified nature; providers must embed imperceptible technical watermarks in addition to visible labels.
•Providers must not be used to create or disseminate disinformation, fake news, content that endangers national security, content that defames individuals, or content that infringes on personal information or portrait rights.
•Content generated using the likeness, voice, or biometric data of a real person requires the prior explicit consent of that individual.
•Providers that reach significant-influence thresholds must complete a security assessment with the CAC and register their algorithms with the authority.
•Providers must maintain logs of deep synthesis activities, including user identity records and content metadata, for a minimum prescribed period (typically not less than six months in connected regulations, and consistent with Cybersecurity Law obligations).
•Providers must implement content-moderation systems capable of detecting and blocking prohibited deep synthesis outputs before distribution.
•Training data used to build deep synthesis models must be sourced lawfully, respecting intellectual property rights and personal-information-protection obligations under PIPL and the Data Security Law.
•Providers must establish and publish complaint and reporting mechanisms allowing users to flag suspected illegal or harmful synthetic content.
•Overseas providers whose services are accessible in China and reach relevant user thresholds are within scope and must designate a domestic compliance representative or establish a local entity.

Who It Affects

Technology companies and AI developers in China offering any generative-media, voice-synthesis, face-swap, or virtual-avatar functionalityDomestic and international platforms distributing user-generated content that may include AI-synthesised mediaAdvertising agencies and brand owners using AI-generated or AI-modified imagery, voice, or video of real persons for campaigns targeting Chinese consumersMedia, entertainment, and streaming companies deploying AI dubbing, de-aging, or virtual presenter technologies for Chinese-market contentCustomer experience and contact-centre operators using AI-generated voice or avatar agents to interact with users in ChinaGaming companies and metaverse platform operators using deep synthesis to create or animate virtual characters or scenesNews and journalism platforms distributing AI-assisted or AI-generated articles, headlines, or multimedia in ChinaAPI providers and model vendors whose deep synthesis capabilities are integrated into third-party products serving the Chinese marketMultinational enterprises with any product feature, workflow, or third-party integration that generates synthetic media accessible to users in China

Effective Date

2023-01-10

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