The Government of India has, for the first time, formally proposed to regulate synthetically generated content, including deepfakes, within India’s existing legal framework. On 22 October 2025, the Ministry of Electronics and Information Technology (MeitY) released proposed amendments to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, introducing clear obligations on intermediaries and AI platforms concerning the creation, distribution, and visibility of synthetically generated information. 

 Why This Matters?  

The seamless integration of Generative AI tools into our society has transformed how content is created online, but it has also opened ways for manipulated media, impersonation, misinformation, and electoral interference. The initial excitement generated around the abilities of AI to create content which is indistinguishable from real content, paved way to concerns of its misuse and the need for fast paced regulation. Until now, Indian law has not regulated such risks, particularly those posed by synthetically generated media, such as deepfakes that convincingly simulate real people’s voices or appearances, on a case-to-case basis, which creates uncertainty and leads to misrepresentation of synthetic content as authentic media.  

By situating these provisions inside the IT Rules 2021, MeitY is extending the compliance framework for intermediaries and platforms that enable or host AI-generated content. This ensures that synthetic content is addressed within India’s existing safe-harbour and due-diligence regime, while we wait for a new comprehensive law regulating AI.  

 Key Provisions Introduced 

The notification published by MeitY on 22 October 2025 sets out a series of proposed changes to the IT Rules 2021.  

1. Definition of “synthetically generated information” (New Rule 2(1)(wa)) 

The proposed amendment adds a new clause in Rule 2, defining synthetically generated information, which refers to information that is artificially or algorithmically created, generated, modified or altered using a computer-resource, in a manner that appears reasonably authentic or true.   

2. Statutory protection for intermediary removal (Proviso to Rule 3(1)(b)) 

The proposed amendments clarify that intermediaries who remove or disable access to synthetically generated information on the basis of user-grievances or reasonable efforts will continue to enjoy the safe-harbour protections under Section 79(2) of the IT Act. In short: acting in good faith against synthetic content is explicitly preserved.   

 3. Due diligence obligations for intermediaries offering creation/modification tools (New Rule 3(3)) 

Intermediaries that enable creation or modification of synthetically generated information (i.e., platforms/tools that allow users to create synthetic content) must: 

A. Ensure any synthetic content is labelled or embedded with a permanent unique metadata or identifier. 

B. The label/identifier must be visibly displayed (for visuals) covering at least 10% of the screen’s surface area, or for audio content, audible within the initial 10% of its duration.   

C. Prohibit modification, suppression or removal of such labels/identifiers by the intermediary.   

 4. Enhanced obligations for Significant Social Media Intermediaries (SSMIs) (New Rule 4(1A)) 

The amendments also propose that SSMIs must: 

A. Obtain from each uploader a declaration whether the information uploaded is synthetically generated.  

B. Deploy “reasonable and proportionate technical measures” to verify the accuracy of such declarations. 

C. Ensure that synthetically generated information is clearly labelled or accompanied by a notice.   

 5. Visibility and audibility standards 

A. For visual synthetic content: the label must cover at least 10% of the visual area and be permanently embedded or clearly visible.   

B. For audio synthetic content: the label or audible notice must appear during the first 10% of the clip’s duration.   

 Implications for Businesses 

The draft amendments define obligations that will cascade across multiple types of entities.  

Here’s a breakdown of who will be impacted and what they will need to do: 

 1. Social Media Intermediaries (SMIs) and Significant Social Media Intermediaries (SSMIs) 

A. SSMIs (which are already defined under the IT Rules 2021 as those with large user-bases and other criteria) will face the enhanced obligations under new Rule 4(1A). They must collect user declarations about synthetic content, deploy technical verification measures and label synthetic content clearly. 

B. SMIs more broadly (platforms that host user-generated content) will also be subject to the intermediary due-diligence obligations generally (and now specifically with respect to synthetic content) so long as they enable or host creation/distribution of synthetic media. 

C. In practical terms, major platforms such as YouTube, Instagram, X (formerly Twitter), Indian short-form video apps, etc, will need to incorporate capabilities to ask for user declarations, verify uploads, label synthetic media, embed metadata, and track provenance.    

2. Platforms / Tools Enabling Creation or Modification of Synthetic Content 

A. Any intermediary that offers “computer resource(s) enabling creation or modification of synthetically generated information” now has a specific duty under Rule 3(3). That means generative-AI tool providers, image/voice synthesis services, content-editing platforms, etc. must ensure that synthetic output is permanently marked or embedded with unique metadata/identifier and that the label cannot be suppressed or removed.   

B. For example, if a company provides voice-synthesis APIs, or image-generation services, those services will need to embed an identifier or watermark that covers at least 10% of the display or initial audio duration, so end-users or consumers know the content is synthetic. 

 C. Digital Media / Marketing / Advertising Companies Using Synthetic Content 

Entities that use synthetic content in marketing, influencer campaigns, digital ads will need to ensure compliance with the labelling/metadata rules. They would need to treat synthetic modifications as such, ensure marking, and ensure platforms hosting their content treat it accordingly. 

 3. Cloud / Data Infrastructure Providers Supporting AI Models 

While perhaps not always explicitly targeted, the infrastructure layers (cloud, datacentres, model providers) supporting generative-AI may come under indirect obligation via the upstream requirement for traceability, metadata embedding and ensuring that intermediaries enable traceability of synthetic output. 

 Additional Duties for Social Media and Large Platforms 

Under the new Rule 4(1A), Significant Social Media Intermediaries (SSMIs), such as YouTube, Instagram, X face heightened compliance requirements. Before publication, they must: 

1. Obtain a user declaration confirming whether uploaded content is synthetically generated. 

2. Deploy automated or technical verification tools to validate such declarations. 

3. Clearly label verified synthetic content prior to publication. 

4. Failure to comply can lead to loss of safe-harbour protections under Section 79 of the IT Act, exposing platforms to regulatory penalties and legal liability.​ 

The SSMI’s will have to reasonably ensure that proportionate technical measures are to verify the correctness of the user declaration.  

Why Inclusion in the IT Act Framework Is Significant 

Embedding these duties within the IT Act’s enforcement architecture ensures continuity with India’s established digital-governance model. The IT Rules already define intermediaries’ due diligence duties; by adding synthetic-media controls, India effectively creates a legal bridge between data protection, platform responsibility, and AI ethics, without drafting an entirely new statute. 

This approach keeps India aligned with global regulatory momentum (EU AI Act, US AI Executive Order) while remaining technologically neutral. It signals that AI governance in India is now a core compliance issue, not an abstract policy debate.