Compliance CN

AI Content Labelling and Content Safety

Labelling is not about announcing that AI made this. It is about being able to trace the content after it has been forwarded, cropped and re-edited.

Labelling is tested after the content travels, not at publication

The Measures for the Labelling of AI-Generated Synthetic Content and the mandatory national standard GB 45438-2025 took effect on 1 September 2025. Most companies’ first instinct is to add “AI generated” in a corner. What regulators and platforms actually test is different: after the content has been downloaded, forwarded, re-edited and uploaded again, can you still show which service produced it and who generated it.

That requires two layers. Visible labels face the user, placed on the content or in the interface so they can be perceived. Implicit labels face traceability, written into file metadata or a watermark. With visible labels only, a screenshot loses provenance; with implicit labels only, users are never informed — neither satisfies the requirement alone.

Obligations are also distributed. Generation service providers, distribution platforms and app stores each carry obligations at different points, and AI companies often occupy the first two at once.

What we do


Typical situations

Situation 1: AI short film distributed without its label

The producer adds an “AI generated” notice at the end card, but the distributor trims it for platform length. After launch the content is ordered to be corrected, and producer and distributor blame each other.

Our approach: place the visible label within the content itself or on a persistent frame rather than the end card; prohibit removal in distribution agreements; spot-check each distribution channel.

Situation 2: Metadata stripped by the platform

Images carry implicit labels, but metadata is lost after compression on a social platform. In a copyright dispute the company cannot prove the content came from its own model.

Our approach: use a robust watermark that does not depend on metadata, and retain generation logs (request ID, model version, timestamp) as an independent evidential chain.

Situation 3: AI companion product accused of targeting minors

The product has no age assurance. A minor uses it for long sessions and makes purchases. Following a parental complaint, the regulator asks what protections are in place.

Our approach: implement age assurance and minor mode, restrict purchases and session length, establish parental request and content grading procedures, and keep records of interventions.


Process and deliverables

StageWorkDeliverables
1Product flow review, obligation mappingObligation checklist + labelling scheme
2Visible and implicit label implementationLabelling specification + technical notes
3Content safety and moderation rulesModeration policy + handling workflow
4Minor protection and response mechanismMinor mode plan + incident playbook
OngoingRule monitoring, spot checks, trainingSpot-check reports + training records

Frequently asked

Must all AI-generated content be labelled? Providers of generated content services must label their output. The precise scope of visible and implicit labels depends on content type and service form; not every scenario requires the same intensity.

Is a visible label enough? No. Visible labels inform users; implicit labels enable traceability. Enforcement and platform verification generally look at both.

Users generate content with our model — who is liable? The provider bears obligations for its service. Users who remove labels and redistribute separately bear their own liability. Terms should prohibit removal, and technical traceability should be retained.

Does labelling hurt the product experience? Somewhat. The goal is a balance between compliance and experience — placement, transparency and presentation can all be tuned, but the label cannot be omitted.


Frequently Asked Questions

Which AI-generated content must be labelled?

Under the measures on labelling AI-generated synthetic content, explicit labels are required and implicit labels must be embedded in file metadata.

How are implicit labels implemented?

Write generation information into file metadata and retain machine-readable fields on distribution platforms; a visible watermark alone is not sufficient.

What are the consequences of not labelling?

Rectification orders, removal or penalties, and platforms may throttle or delete unlabelled content.

Related Case Studies

All cases →

Each case states the obligation triggered, the judgment we made, and what was delivered.

Further Reading

Rule changes, enforcement cases and practical judgments around this service, listed in publication order.

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