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China AI Labelling for legal AI workflows

China AI Labelling in legal AI workflows: what compliance requires, who asks for evidence, and the records to keep.

Legal forceBinding law
Applies from1 Sep 2025
SectorLaw
Checked21 Oct 2026

01 / The rule

What China AI Labelling requires

Generation service providers, content dissemination platforms, app distribution platforms and publishing users already within China's algorithm-recommendation, deep-synthesis or generative-AI service rules.

  1. 01Generation providers: write an implicit metadata label with generation attribute, provider name or code, and content number into every file.
  2. 02Apply an explicit, perceptible label where the service falls under Deep Synthesis Provisions Art. 17(1), and keep it on download, copy and export.
  3. 03Dissemination platforms: verify metadata, show a notice for generated, declared or suspected content, and write their own provenance fields into the file.
  4. 04App stores: ask whether an app offers AI generation services and check its labelling materials at listing or launch review.
  5. 05If supplying unlabelled content on request, fix the user's labelling duty in the agreement and keep logs for at least six months.
  6. 06Publishing users must declare generated content; no one may maliciously remove, alter, forge or conceal labels.

02 / In this sector

In a legal AI workflow

Applies directly to AI-generated text, images, audio, video and virtual scenes. Scope is derivative: it reaches only services already covered by China's three upstream AI and algorithm rules.

Usually asked by

General counsel and litigation support.

Named alongside

FRE 702 · ABA Model Rules.

Sector pagePlanisphere for law

03 / Records

Records to keep

  1. 01Metadata label schema and per-format embedding test results against GB 45438-2025
  2. 02Export tests showing explicit labels survive download and copy
  3. 03User agreements fixing labelling duties for unlabelled supply
  4. 04Recipient logs for unlabelled supply retained at least six months

Optional evidence · where Planisphere fits

Keep a record anyone can check

When your team meets a duty, Planisphere can seal the event it reports as a receipt.

01 · Your teamRecord the event

A disclosure shown, a review signed, a model change approved: the event your system reports.

02 · PlanisphereSeal it

The event becomes a sealed receipt, dated and attributed to whoever is signed in.

03 · AnyoneCheck it

Paste the receipt into Verify. No account or key.

A record supports your compliance evidence process. It is not a legal finding or a certification. Systems that call Planisphere's gate API can also hold or refuse an action before it runs.

SOURCES

Go back to the source

PRIMARY
Official questions and answers on the Measures

Cyberspace Administration of China

PRIMARY
SECONDARY

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