Deep synthesis technology is a priority area of AI regulation. Products such as face swapping, voice cloning and virtual humans that launch without filing face removal, fines and in serious cases shutdown.
The legal basis for deep synthesis filing
Core regulation: Provisions on the Administration of Deep Synthesis of Internet Information Services (Order No. 12 of the CAC and two other authorities, effective 10 January 2023)
Article 19:
A provider of deep synthesis services with public-opinion attributes or the capacity for social mobilisation shall complete filing and the formalities for change and cancellation of filing in accordance with the Provisions on the Administration of Internet Information Service Algorithmic Recommendations. A technical supporter of deep synthesis services shall complete filing and the formalities for change and cancellation of filing by reference to the preceding paragraph.
Key points:
- Deep synthesis service providers must file
- Deep synthesis service technical supporters must also file, by reference to the algorithm recommendation provisions
- Filing is made through the unified system at beian.cac.gov.cn
- The filing number must be displayed conspicuously on the website or app
Which products require deep synthesis filing
Services that must file
| Service type | Typical products | Filing required |
|---|---|---|
| Face swapping | Face-swap apps, mini-programs, video face-swap tools | Yes |
| Voice cloning | AI dubbing, voice cloning, speech synthesis | Yes |
| Virtual humans or digital humans | Virtual anchors, digital customer service, virtual idols | Yes |
| AI image or video generation | Text-to-image, text-to-video, AI photo editing | Yes |
| Deep synthesis SDKs and APIs | Interfaces providing face swapping, voice cloning and similar functions | Yes |
| AI filters and effects | Beauty filters, age change, gender swap | Yes, where public-opinion attributes are present |
Circumstances not requiring filing
- Use solely for internal research and testing, without services to the public
- Personal, non-commercial use that does not amount to “providing a service”
- Algorithm filing already completed through another route that covers the deep synthesis function
The core duties of a deep synthesis provider
Duty one: algorithm filing
File through beian.cac.gov.cn within ten working days from the date services begin. The process follows algorithm recommendation filing; see the complete guide to algorithm filing.
Duty two: labelling of AI-generated content
Legal basis: Articles 16 and 17, Provisions on Deep Synthesis
A deep synthesis service provider shall:
- Add labels to generated or edited information content so that the public can identify it as deep synthesis content
- Add watermarks or metadata marks to generated or edited images and videos
- Add voice prompts or metadata marks to generated or edited audio
- Display, in a conspicuous position on apps and websites offering deep synthesis functions, a prompt requiring users to comply with laws and regulations
Labelling methods:
| Content type | Method |
|---|---|
| Images | Visible watermark plus invisible watermark in metadata |
| Video | On-screen label plus metadata mark |
| Audio | Voice prompt, for example “this audio was generated by AI”, plus metadata mark |
| Text | Metadata mark, with a visible label optional |
Duty three: real identity verification
A deep synthesis service provider shall carry out real identity verification of users. Deep synthesis services may not be provided to users whose identity has not been verified.
Duty four: content review and risk control
- Establish a mechanism for handling unlawful content
- Establish complaints and reporting channels
- Retain deep synthesis logs for at least six months
- Establish a contingency response plan
Specific points for filing documents
Deep synthesis filing builds on the standard algorithm filing documents, with particular attention to the following:
| Document section | Specific point for deep synthesis |
|---|---|
| Algorithm description | The type of synthesis technology must be specified: image generation, speech synthesis, video replacement and so on |
| Data sources | Biometric information such as faces and voices in training data requires separate consent |
| Risk assessment | The risk of “impersonating another person” and the response must be assessed |
| Content labelling | The technical solution for labelling AI-generated content must be described in detail |
| User verification | The technical solution for real identity verification must be described |
Enforcement cases
Case one: removal of a voice-cloning application (2024)
Product: “Reecho”, an AI voice-cloning tool Breach: unrestricted cloning of public figures’ voices; no filing or registration record; no mandatory labelling of AI-generated content Outcome: removed simultaneously from app stores and mini-programs nationwide, with a deadline imposed for filing, registration and security review
Case two: the Shanghai “Liangjian Pujiang” enforcement action (2025)
Breach: several companies developed and used generative AI functions without conducting the required security assessments, resulting in “face swapping and voice changing” and “disguise and fabrication” that infringed personal information rights, the production of “doxxing” and “money laundering” content, and pornographic or vulgar images Outcome: three AI service websites were placed under investigation and penalised, the first application of the Interim Measures for the Administration of Generative Artificial Intelligence Services
Case three: removal of a face-swapping app (2025)
Breach: an AI face-swapping app operated by a technology company in Zhejiang failed to perform deep synthesis filing and security assessment duties Outcome: the service was ordered offline with a deadline for rectification
Compliance action checklist
| No. | Action | Recommended timing |
|---|---|---|
| 1 | Determine whether the product constitutes a deep synthesis service | Week 1 |
| 2 | Complete entity filing at beian.cac.gov.cn | Weeks 1–2 |
| 3 | Deploy the AI-generated content labelling system, with watermark and metadata | Weeks 2–4 |
| 4 | Implement real identity verification for users | Weeks 2–4 |
| 5 | Complete the algorithm security self-assessment report | Weeks 3–6 |
| 6 | Submit the algorithm filing application | Week 6 |
| 7 | Establish content review and complaints handling mechanisms | Ongoing |
| 8 | Retain deep synthesis logs for at least six months | Ongoing |
Frequently asked questions
Q: We only use a third-party SDK for face swapping. Is filing required? A: Yes. Even where third-party technology is used, a product that provides deep synthesis services to users must file as a service provider. The technology provider must also file by reference to the provisions.
Q: Do AI filters count as deep synthesis? A: A filter that only adjusts colour or brightness is not deep synthesis. Functions that alter facial features, such as face replacement, age change or gender swap, do constitute deep synthesis and require filing.
Q: May we operate on a trial basis during filing? A: Strictly, services may be offered to the public only after filing is complete. A soft launch may be run for internal users or external testers who have signed informed consent, but should not be opened to unspecified members of the public.
Q: Is there a unified standard for labelling AI-generated content? A: Articles 16 and 17 of the Provisions on Deep Synthesis currently provide the basic requirements. More detailed labelling standards may be issued by the CAC in 2026, and should be monitored.
This article is prepared on the basis of the Provisions on the Administration of Deep Synthesis of Internet Information Services and published enforcement cases. For assistance with deep synthesis filing, please contact Geason Law Offices.