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Question · China AI Labelling

How long must China AI labelling records be kept?

Issued by the Cyberspace Administration of China with MIIT, the Ministry of Public Security and the NRTA, the Measures require a visible label on certain AI-generated content and a metadata label on all of it, with duties running along the whole distribution chain.

AboutChina AI Labelling
Legal forceBinding law
Applies from1 Sep 2025
Checked21 Oct 2026

01 / The answer

The short answer

At least six months, in one specific case. Under Article 9 of the Measures, a provider may supply generated content without a visible label when a user asks for it, but only if the user agreement first sets out the user's own labelling duties. The provider must then keep logs, including information on who received the content, for at least six months. The Measures do not set a general retention period for other labelling records.
China AI Labelling · checked 21 Oct 2026

02 / The rule

What China AI Labelling requires

Issued by the Cyberspace Administration of China with MIIT, the Ministry of Public Security and the NRTA, the Measures require a visible label on certain AI-generated content and a metadata label on all of it, with duties running along the whole distribution chain. GB 45438-2025 fixes the technical labelling method, including the metadata format.

  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.

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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Related: China AI Labelling: the full guide · What does China require for labelling AI-generated content?