On 8 September 2023 the Ministry of Industry and Information Technology, the Ministry of Education, the Ministry of Culture and Tourism, the State-owned Assets Supervision and Administration Commission and the National Radio and Television Administration jointly issued the Three-Year Action Plan for Innovative Development of the Metaverse Industry (2023-2025). The plan targets breakthroughs by 2025 in metaverse technology, industry, applications and governance, with tasks across key technology, infrastructure, scenarios, industrial ecosystem and governance.
Industrial policy provides direction and resources, not a compliance exemption. Companies entering metaverse business need to answer at least five compliance questions.
Digital humans and deep synthesis
Avatars, digital anchors and AI customer service often involve deep synthesis. Under the deep synthesis provisions, functions that generate or materially alter information content must be labelled; services with public-opinion attributes or social mobilisation capacity also require algorithm filing and security assessment.
Where a digital human uses a real person’s likeness or voice, portrait rights, voice rights and personal information are engaged. Authorisations should specify scope, term, platforms and whether retraining is permitted, avoiding vague “one authorisation, unlimited use” clauses.
Virtual assets and financial risk
Virtual props, virtual land, points and tokens can be confused with virtual currency and token fundraising. Policy expressly targets virtual currency speculation and illegal financial activity. Companies designing virtual asset systems should avoid attributes of tradability, convertibility into fiat currency and speculative appreciation, and avoid creating disguised financing.
Projects marketed as “metaverse real estate” or “digital collectibles” need particular care in advertising. Promising appreciation or implying investment returns may trigger advertising and financial regulation and consumer disputes.
Minors and content governance
Social, gaming, live streaming and virtual performance in the metaverse raise higher requirements for minors. Although the minors’ network protection regulation takes effect on 1 January 2024, its principles are already clear: identify minors, limit spending, prevent addiction and provide age-appropriate content.
For open-world and virtual social products, moderation cannot rely only on user reports. Scenario-based review is needed for text, voice, images and behavioural interaction within virtual spaces.
Data and privacy
VR and AR devices collect eye movement, gestures, spatial location and physiological data, much of which is sensitive personal information. Companies must explain purpose, scope and retention, obtain separate consent and assess whether a personal information protection impact assessment is required.
Spatial data may also involve surveying, geographic information and important data. Projects involving high-precision maps or indoor spatial modelling should assess surveying qualifications and cross-border data requirements.
Intellectual property
Virtual goods, scene design, digital human likeness and user-generated content engage copyright, trademark and design rights. Platforms need complaint and takedown mechanisms and clear rules on ownership and licensing of user content.
Brands should plan trademark coverage for virtual stores, virtual endorsements and digital collectibles in advance. Registrations limited to physical goods may not cover virtual goods and services.
How to start
First, break product features into technology modules and identify deep synthesis, recommendation, virtual assets and spatial data. Second, prepare contract templates for digital human and likeness licensing. Third, assess financial and advertising compliance before designing virtual assets. Fourth, build minors protection into the product rather than patching later. Fifth, register trademarks and copyrights early.
For AI product launch and documentation, see our AI product launch documents service; for data and sensitive information, see data compliance; for likeness and content licensing, see intellectual property.
This article is based on the Three-Year Action Plan for Innovative Development of the Metaverse Industry (2023-2025) issued by five departments on 8 September 2023. It is for reference only and does not constitute legal advice.