ChinaProvisions on the Administration of Deep Synthesis Internet Information Services, Articles 16 and 17
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) issued by CAC, MIIT and MPS, 2022, Arts. 16-17
In force since .
An AI transparency rule binding public and private bodies.
- How the hook was established
- express
- What makes it apply
- Market targeting
- Audit expectation
- none
What it requires
- Label content your service generates or edits, by a technical measure that does not interfere with normal useNIST AI RMFMEASURE 2.8
- Apply a prominent public-facing label where the service simulates dialogue or writing, synthesizes or alters voice, generates or swaps faces, or builds immersive simulated scenesNIST AI RMFMEASURE 2.8
- Retain the log information the Provisions requireno control in the NIST AI RMF
These lines are LexLint's reading of the law's text.
In the frameworks
- NIST AI RMF
- MEASURE 2.8Risks associated with transparency and accountability – as identified in the MAP function – are examined and documented.
Our reading of where this law's duties sit in each framework, and in the NIST AI RMF, line by line beside each duty above. It never says that running a control meets the law. How we read a framework against the law
Who enforces it
Settledness
- As of
- Open questions
- Whose confusion decides whether a service 可能导致公众混淆或者误认 ("could cause public confusion or misidentification") under Article 17, and how is that judged for a service the list does not name?
- What form must the 标识 ("label") added under Article 16 take, given that it need only be one 不影响用户使用 ("that does not affect users' use"), and how does it differ from the 显著标识 ("prominent label") of Article 17?
What it makes you log
Logging duty
Article 16 requires a deep synthesis service provider to apply a technical measure labeling content it generates or edits and, in the same sentence, to retain log information (日志信息) in accordance with law, administrative regulations, and other relevant State provisions. The article names the record directly but states no retention period or content of its own, deferring both to other rules; no numeric period appears anywhere else in this Provisions' text. Article 17, also part of this instrument's citation, adds the public-facing prominent-label duty and states no logging content of its own.
- Kind
- Explicit
- As of
- Provision
- Article 16
- Trigger
- content_generation
What this law does
Deep-synthesis service providers must apply a technical measure to label content generated or edited using their service without interfering with normal use, and retain log information as required.
Where a listed category of service could cause public confusion, simulated dialogue or writing, synthesized or altered voice, face generation or face-swap, or immersive simulated-scene generation, the provider must apply a prominent label alerting the public to the deep-synthesis nature of the content. This is the earliest of China's four labeling instruments and is the one the 2023 Generative AI Interim Measures cross-references.
When LexLint raises it
When your app profile says your app generates content with AI, deploys a chatbot or processes biometric data.
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