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.

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:

Which products require deep synthesis filing

Services that must file

Service typeTypical productsFiling required
Face swappingFace-swap apps, mini-programs, video face-swap toolsYes
Voice cloningAI dubbing, voice cloning, speech synthesisYes
Virtual humans or digital humansVirtual anchors, digital customer service, virtual idolsYes
AI image or video generationText-to-image, text-to-video, AI photo editingYes
Deep synthesis SDKs and APIsInterfaces providing face swapping, voice cloning and similar functionsYes
AI filters and effectsBeauty filters, age change, gender swapYes, where public-opinion attributes are present

Circumstances not requiring filing

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:

  1. Add labels to generated or edited information content so that the public can identify it as deep synthesis content
  2. Add watermarks or metadata marks to generated or edited images and videos
  3. Add voice prompts or metadata marks to generated or edited audio
  4. 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 typeMethod
ImagesVisible watermark plus invisible watermark in metadata
VideoOn-screen label plus metadata mark
AudioVoice prompt, for example “this audio was generated by AI”, plus metadata mark
TextMetadata 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

Specific points for filing documents

Deep synthesis filing builds on the standard algorithm filing documents, with particular attention to the following:

Document sectionSpecific point for deep synthesis
Algorithm descriptionThe type of synthesis technology must be specified: image generation, speech synthesis, video replacement and so on
Data sourcesBiometric information such as faces and voices in training data requires separate consent
Risk assessmentThe risk of “impersonating another person” and the response must be assessed
Content labellingThe technical solution for labelling AI-generated content must be described in detail
User verificationThe 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.ActionRecommended timing
1Determine whether the product constitutes a deep synthesis serviceWeek 1
2Complete entity filing at beian.cac.gov.cnWeeks 1–2
3Deploy the AI-generated content labelling system, with watermark and metadataWeeks 2–4
4Implement real identity verification for usersWeeks 2–4
5Complete the algorithm security self-assessment reportWeeks 3–6
6Submit the algorithm filing applicationWeek 6
7Establish content review and complaints handling mechanismsOngoing
8Retain deep synthesis logs for at least six monthsOngoing

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.

Geason Law Offices AI Industry Research Group | Reviewed by Ho Qianggao