SC-AI-023 · Transparency

Label AI-generated and synthetic content

Medium effortCovered by ISO 27001: New for AISatisfies 11 obligations in 5 policies

What it means

  • Any image, video, audio or text your systems generate or materially alter with AI carries:
    • a visible label (on-screen text, watermark, or a spoken prefix for audio), and
    • embedded provenance (permanent metadata or a unique identifier showing your service made it), where technically feasible.
  • Users must not be able to strip or hide the label or metadata.
  • Platforms that host user uploads ask uploaders to declare synthetic content and show a label before it goes live.
  • ISO 27001 reuse: None. New for AI, not covered by ISO 27001.

Why it matters

  • The 2026 IT Rules amendment makes labelling and permanent metadata for synthetically generated information (SGI) binding on intermediaries, with extra declaration duties for significant social media intermediaries (SSMIs).
  • The MeitY deepfakes advisory already asked for labels or unique identifiers on content that could be misinformation or a deepfake.
  • RBI FREE-AI expects watermarked or clearly labelled digital interfaces for AI in banking channels.
  • Non-compliance can cost intermediaries their safe harbour under Section 79 of the IT Act.

Checklist

  1. Identify every feature that generates or edits media or text with AI (image tools, avatar video, voice cloning, AI copywriting).
  2. Decide label format per media type: visible overlay, caption, audio prefix. Make it prominent, not a tiny corner mark.
  3. Embed provenance metadata (for example C2PA content credentials) and a unique identifier pointing to your service.
  4. Remove any "export without watermark" or "strip metadata" option; test that common edits do not silently drop the label (SC-AI-029 AI-specific security controls (prompt injection, model abuse)).
  5. If you are an SSMI: add an uploader declaration step, a technical check of the declaration (SC-AI-036 Deepfake and impersonation safeguards), and a label before publication.
  6. Log which outputs were labelled and with which identifier (SC-AI-032 Logging and record keeping).
  7. Re-test labels after each model or pipeline change.

Evidence examples

  • Sample outputs showing the visible label and the metadata read by a C2PA or EXIF viewer.
  • Design document for the labelling and provenance pipeline.
  • Test report proving labels survive download, crop and re-encode within reason.
  • Upload flow screenshots showing the SGI declaration (SSMIs).
  • Change records showing label re-testing after model updates.

Common pitfalls

  • Labelling images but forgetting audio and video.
  • Metadata only, with no visible label for ordinary viewers.
  • Premium tiers sold with "no watermark" as a feature.
  • Relying on users to label voluntarily with no technical check.

Satisfies

Also relevant to

Standards crosswalk

Clause references only. Check the standard itself for the exact wording.

ISO/IEC 42001

  • A.8.2 system documentation and information for users
  • A.8.5 information for interested parties

ISO/IEC 27001

No direct equivalent

SOC 2

  • CC2.3

Key takeaways

  • Two layers: a visible label people see and embedded metadata machines read.
  • Users must not be able to remove either; test it.
  • In India this is now binding for intermediaries under the 2026 IT Rules.

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