1.0 Strategic Imperative: Understanding the New AI Identification Mandate

The “Measures for Identification of AI-Generated Synthetic Content,” effective September 1, 2025, represent a pivotal regulatory development in the governance of artificial intelligence. This memo deconstructs these new regulations into a practical, actionable framework designed to guide our compliance strategy. By proactively implementing these measures, we not only ensure regulatory adherence but also build a defensible compliance posture, mitigate brand risk associated with unidentified synthetic media, and establish a competitive advantage built on user trust.

The core objectives of these measures are to promote the healthy development of artificial intelligence, standardize the methods for identifying AI-generated content, and ultimately protect the public interest. The regulations apply broadly to “network information service providers” engaged in activities specified under the existing rules governing algorithm recommendations, deep synthesis, and generative AI services. Adherence is not optional but a foundational requirement for operating in this space. At the heart of these measures is a comprehensive dual-identifier system that creates transparency for both human users and automated systems.

2.0 The Dual Identification Framework: Explicit and Implicit Mandates

The regulations establish a dual-identifier system as a strategic, multi-layered approach to content transparency. This framework is designed to be comprehensive, ensuring that AI-generated content is clearly identifiable to both human end-users (through explicit, perceptible markers) and automated systems (through implicit, machine-readable data). This dual approach is critical for building a trustworthy information ecosystem.
The two core identification types are defined as follows:

Identifier Type	Definition & Purpose
Explicit Identifiers	User-perceptible markers presented as text, graphics, or sound. Their purpose is to inform the end-user directly and unambiguously that they are interacting with AI-generated content.
Implicit Identifiers	Machine-readable technical measures, such as metadata or digital watermarks, embedded directly into the content file. Their purpose is to enable programmatic verification, tracking, and enforcement by platforms and authorities.

This dual framework creates a chain of custody: the implicit identifier acts as a permanent, machine-readable signal of origin, which then triggers the application of a user-facing explicit identifier by downstream platforms. The following sections provide detailed implementation guidelines for both AI service providers who create content and the content propagation platforms that host it.

3.0 Implementation Guide for AI Service Providers (Content Creators)

This section provides specific, media-centric guidance for organizations whose services are used to generate or synthesize AI content. These obligations, detailed in Articles 4 and 5, focus on embedding the required identifiers at the moment of creation.

3.1 Prescribing Explicit Identifiers (Article 4)

Service providers must apply explicit identifiers to generated content according to its type. The following requirements are mandatory:

• Text: Add text or symbol prompts at the beginning, end, or another appropriate middle location. Alternatively, a prominent prompt may be added in the user interface or around the text.
• Audio: Add voice prompts or distinct audio rhythm cues at the beginning, end, or an appropriate middle point of the audio track.
• Images: Add a prominent prompt in an appropriate and visible location on the image itself.
• Video: Add a prominent prompt on the start screen and in an appropriate location around the playback area. Prompts may also be added in the middle or at the end of the video.
• Virtual Scenes: Add a prominent prompt on the initial screen and, where applicable, at appropriate points during the ongoing service experience.
• Other Scenarios: For other generative service scenarios, add prominent prompts according to the application’s own specific characteristics.

Crucially, these explicit identifiers must be retained within the content file when a user downloads, copies, or exports it from the service. This necessitates a cross-functional effort between our product, design, and engineering teams to develop a consistent and user-friendly identification design language that meets these diverse media requirements without degrading the user experience.

3.2 Embedding Implicit Identifiers (Article 5)

In addition to visible markers, service providers are mandated to add implicit identifiers to the file metadata of all generated content. This metadata must include the following essential components:

• Information noting the content’s AI-generated attribute.
• The name or a unique code identifying the service provider.
• A content-specific number or unique ID.

For clarity, the regulations define file metadata as “descriptive information embedded in the file header according to a specific encoding format, used to record information such as the file’s source, attributes, and purpose.” The regulations also explicitly encourage the adoption of additional technologies, such as digital watermarking, to further strengthen these implicit identification measures.

These embedded implicit identifiers are not merely a creator-side obligation; they are the critical technical signals that enable content propagation platforms to fulfill their own distinct responsibilities, which we will now detail.

4.0 Responsibilities for Content Propagation Platforms (Content Hosts)

Platforms that host and disseminate user-generated content, such as social media networks and video-sharing sites, have distinct responsibilities for managing the information ecosystem. The obligations outlined in Article 6 are critical for ensuring that AI content remains identifiable as it spreads across the internet. Platforms must implement a clear protocol for handling uploads based on the presence (or absence) of identifiers.

The required actions are summarized below:

Scenario	Required Action	Metadata Obligation
AI Content Detected via Implicit Identifier	Add a prominent explicit label to the content, clearly informing the public that it is AI-generated.	Add propagation metadata including: content attribute information, platform name or unique code, and a content-specific ID.
User Declares Content is AI-Generated (No Identifier)	Add a prominent label stating the content may be AI-generated, based on the user’s declaration.	Add propagation metadata including: content attribute information, platform name or unique code, and a content-specific ID.
Platform Detects AI Traces (No Identifier or Declaration)	If AI-generation traces are detected, add a label stating the content is suspected to be AI-generated.	Add propagation metadata including: content attribute information, platform name or unique code, and a content-specific ID.

In addition to these reactive measures, platforms must provide users with a clear and accessible function to voluntarily declare and label their uploads as AI-generated content. These platform-level duties must be supported by clear policies governing user interactions and agreements.

5.0 Managing User Agreements, Exemptions, and Obligations

To ensure legal clarity and effectively manage user responsibilities, it is essential to codify our AI content policies within user-facing agreements. The regulations in Articles 8, 9, and 10 provide a clear mandate for establishing these rules of engagement with our users.
The following key policy points must be integrated into our user service agreements:

• Clear Disclosure (Article 8): The agreement must clearly explain the platform’s methods, styles, and rules for AI content identification so users understand their obligations and how the platform operates.
• User Declaration Duty (Article 10): Users must be contractually obligated to actively declare AI-generated content upon upload, using the platform’s designated tools and functions.
• Prohibition on Tampering (Article 10): The agreement must strictly prohibit any user from maliciously deleting, altering, forging, or hiding the required identifiers. This prohibition extends to providing tools or services that enable such actions.
• Process for Exemption (Article 9): A formal protocol must be established for users who request content without explicit identifiers. This is only permissible after the user’s obligations and responsibilities are clearly defined in a user agreement. Furthermore, logs of these requests, including information on the recipient, must be retained for at least six months. This exemption process must be tightly controlled and treated as a high-risk activity, with clear criteria for approval and robust logging to ensure full auditability.

Integrating these terms into our user agreements forms the legal backbone of our compliance efforts and prepares us for broader regulatory duties.

6.0 Fulfilling Broader Compliance and Reporting Mandates

Beyond feature-level implementation and user agreements, the regulations require the integration of these identification measures into our organization-wide compliance and reporting workflows. This includes aligning with existing regulatory processes, such as security assessments and app store review cycles.

The following high-level actions are required to ensure full compliance:

• App Store Disclosure (Article 7): When submitting or updating applications on any app distribution platform, we must formally declare if the app provides AI generation services. We must also be prepared to present materials detailing our identification methods for verification during the review process.
• Regulatory Filings (Article 12): We must include comprehensive materials detailing our content identification measures as part of our mandatory algorithm filing (备案) and security assessment procedures.
• Information Sharing (Article 12): We are required to support information sharing initiatives to assist authorities in preventing and combating illegal activities related to AI-generated content.

To ensure readiness for the September 1, 2025 enforcement date, leadership must immediately charter a cross-functional compliance task force. Key initial actions include a comprehensive audit of all services with generative capabilities, a legal review and update of our user service agreements, and the formal integration of these identification requirements into our product development lifecycle. Proactive and thorough compliance is not merely a legal obligation but a strategic imperative for responsible innovation in the age of AI.