China requires marks on synthesised content
On 10 January 2023 the Internet Information Service Deep Synthesis Management Provisions took effect, promulgated on 25 November 2022 as joint Order No. 12 of three agencies. Article 16 requires a provider to add to everything generated or edited with its service a technical mark that does not interfere with use, and to keep logs; article 17 adds a conspicuous mark where the synthesis could mislead the public.
Why it matters
This is the first binding duty to mark machine-generated content as such. There is not one mark here but two, and they do different jobs: one travels with the file always and is addressed to an investigator, the other sits in plain view and is addressed to a viewer. Later regimes in other countries repeat that split.
The provisions were adopted at the Cyberspace Administration's 21st office meeting on 3 November 2022 and signed by the Cyberspace Administration, the Ministry of Industry and Information Technology and the Ministry of Public Security. Article 23 lists six classes of covered technology: text generation, style transfer and dialogue; speech synthesis and voice conversion; music and scene-sound generation; face generation, face swapping and control of face and posture; image generation, enhancement and restoration; three-dimensional reconstruction and digital humans. Article 9 requires verification of a user's real identity by phone number, identity document or unified social credit code, and forbids offering publication services to an unverified user. Article 14 separately requires a provider of face or voice editing to have the user notify the person whose features are being edited and obtain their separate consent. Article 18 forbids anyone to delete, tamper with or conceal the marks required by articles 16 and 17. What the record does not claim. The conspicuous mark under article 17 is not a blanket duty: it attaches to the services listed there and only where the synthesis could cause confusion or misidentification. The report this candidate came from had articles 16 and 17 the wrong way round, assigning the conspicuous mark to article 16 and the hidden one to article 17; the text of the rule says the opposite. The record names no penalty figure and no enforcement.