India's New Frontier In Digital Content And AI Regulation: Navigating The Synthetically Generated Information Regulation Under The Information Technology (Intermediary Guidelines And Digital Media Ethics Code) Amendment Rules, 2026

India's digital and AI regulatory framework has entered a decisive new phase. On 10 February 2026, the Ministry of Electronics and Information Technology (“MeitY”) notified the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Amendment Rules, 2026, introducing a comprehensive regulatory framework specifically addressing Synthetically Generated Information (“SGI”). These amendments, which took effect on 20 February 2026, mark India's response to the proliferation of deepfakes, AI-generated content, and other forms of synthetic media that can deceive users and cause significant harm.

For intermediaries, social media platforms, content creators, and technology companies operating in India's digital ecosystem, these amendments are not merely incremental updates. They represent a fundamental shift in regulatory expectations, imposing stringent due diligence obligations, accelerated compliance timelines, and heightened accountability measures. The regulatory framework seeks to balance the dual objective of protecting users from synthetic content misuse while encouraging responsible innovation in artificial intelligence technologies.

I.         Understanding Synthetically Generated Information: Definition and Scope

a) What Constitutes SGI?

Under the amended Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“IT Rules”), “synthetically generated information” is defined as audio, visual or audio-visual information which is artificially or algorithmically created, generated, modified or altered using a computer resource, in a manner that such information appears to be real, authentic or true, and depicts or portrays any individual or event in a manner that is, or is likely to be perceived as indistinguishable from a natural person or a real-world event.

In simpler terms, SGI refers to synthetic artificial media that can realistically appear like a real natural person (including their appearance or voice) or a real-world event, in a way that may deceive viewers into believing that it is genuine. This encompasses what is commonly referred to as deepfakes, AI-generated or AI-altered images and videos, voice cloning, and other forms of realistic synthetic audio-visual content.

b)     SGI Definition restricted to Audio-Visual Content

A crucial aspect of the SGI framework is its scope limitation. The definition specifically applies to “audio, visual or audio-visual information” and does not extend to pure text or written outputs. Text-only AI outputs, by themselves, are not classified as SGI, though intermediaries' general due diligence obligations regarding unlawful information continue to apply regardless of content format. However, the amendments also clarify that references to “information” in the context of unlawful acts shall include SGI, ensuring that unlawful acts involving synthetic audio-visual content are clearly covered, even where such SGI is accompanied by text captions, descriptions, or posts.

c)     What is Excluded from the SGI Definition?

Recognising that SGI technologies can deliver significant benefits such as innovation, accessibility and inclusive digital growth, the rules provide specific exclusions to ensure that routine, good-faith uses of AI or other technologies are not unnecessarily regulated. The following categories are expressly excluded from the SGI definition:

• Routine or Good-Faith Editing and Enhancement: Routine actions such as editing, formatting, enhancement, technical correction, colour adjustment, noise reduction, transcription, or compression are excluded, provided such actions do not materially alter, distort, or misrepresent the substance, context or meaning of the underlying content.

Examples include increasing brightness or contrast, compressing videos, removing background noise, transcribing audio, or stabilising shaky footage.

• Routine Creation of Documents and Presentations: The routine or good-faith creation, preparation, formatting, presentation or design of documents, presentations, PDF files, educational or training materials, and research outputs (including the use of illustrative, hypothetical, draft, template-based or conceptual content) is excluded, provided such creation does not result in the creation or generation of any false document or false electronic

This covers PowerPoint presentations, illustrative diagrams, hypothetical case studies, and formatted reports.

• Accessibility and Translation Tools: The use of computer resources solely for improving accessibility, clarity, quality, translation, description, searchability, or discoverability is excluded, provided the process does not generate, alter, or manipulate any material part of the underlying audio, visual or audio-visual information.

This includes adding subtitles, closed captions, translating content, auto-generating summaries for searchability, and providing audio descriptions for visually impaired users.

II.          Addressing the Risks of SGI Misuse

The Government of India has explicitly recognised that synthetic information, when developed and used responsibly, offers significant benefits by enabling innovation, accessibility, and economic growth across sectors. These technologies support the creation of multilingual and local-language content, improve access to education through personalised learning tools, enhance public service delivery, and promote inclusion through assistive technologies for persons with disabilities.

However, the amendments were introduced in view of rapid advances in artificial intelligence and machine learning technologies, which have made it significantly easier to create, generate, modify or alter highly realistic synthetic audio-visual content, including deepfakes, that can mislead or deceive users.

The regulatory framework identifies several serious harms arising from SGI misuse:

• Misinformation and Disinformation: The spread of false information and erosion of public trust in authentic content.
• Impersonation and Identity Fraud: Deceptive portrayal of individuals making statements or taking actions they never did.
• Non-Consensual Intimate Imagery: Creation and distribution of sexually explicit synthetic content without consent, including obscenity and child sexual exploitative and abuse material (“CSEAM”).
• Reputational Harm: Coercion, extortion, and severe psychological impact on victims of synthetic content

Accordingly, to ensure an Open, Safe, Trusted and Accountable Internet, the amendments seek to strengthen the IT Rules by addressing the unique risks posed by SGI in a clear and enforceable manner.

III.         Core Obligations for Intermediaries

a) Enhanced User Awareness and Periodic Notifications

Under the amended Rules, intermediaries must inform users at least once every 3 months (reduced from the earlier once in 12 months requirement) about important obligations, compliance with platform legal terms and consequences relating to their use of the intermediary's platform or services. This periodic user information must include:

• The intermediary's right to terminate or suspend user access, or remove information or disable access to information, for non-compliance with the Rules or terms.
• User liability for unlawful acts and for violating applicable
• Where applicable, the intermediary's obligation to report offences that are mandatorily reportable under law.

b)     Dedicated SGI Due Diligence Framework

The amendments introduce a new Rule titled “Due diligence in relation to synthetically generated information”, which constitutes the core operative framework for addressing SGI. This rule applies to any intermediary offering a computer resource enabling or facilitating the creation, generation, modification, alteration, publication, transmission, sharing or dissemination of SGI.

Covered intermediaries include those offering AI image/video generation or editing tools, voice synthesis or voice cloning tools, platforms enabling manipulation of audio-visual information into realistic synthetic media, and platforms that facilitate publication or dissemination of SGI.

Prevention of Unlawful SGI

Intermediaries covered must deploy reasonable and appropriate technical measures, including automated tools or other suitable mechanisms, to prevent users from creating, generating, modifying, altering, publishing, transmitting, sharing or disseminating SGI that violates any law for the time being in force.

The Rule expressly requires prevention of high-risk unlawful SGI, including:

• CSEAM and Non-Consensual Intimate Imagery: Child sexual exploitative and abuse material, non- consensual intimate imagery, obscene, pornographic, paedophilic, or sexually explicit content, including content invasive of bodily privacy.
• False Documents and Electronic Records: SGI resulting in the creation, generation, modification, or alteration of any false document or false electronic record.
• Dangerous Materials: SGI relating to the preparation, development, or procurement of explosive material, arms or ammunition.
• Deceptive Impersonation and Misrepresentation: SGI that falsely depicts or portrays a natural person or a real-world event by misrepresentation likely to deceive, including misrepresentation of identity, voice, conduct, action or statement, or the event itself.

Mandatory Labelling and Provenance Requirements

For SGI that is not prohibited (i.e., permissible SGI), intermediaries must ensure that such content is:

• Clearly and Prominently Labelled: Visual or audiovisual content must display a prominently visible label, while audio content must include a prominently prefixed audio disclosure (such as “This audio is synthetically generated”).
• Embedded with Permanent Metadata and Identifiers: To the extent technically feasible, permissible SGI must be embedded with permanent metadata or technical provenance mechanisms, including a unique identifier, to enable identification of the content as SGI and identification of the computer resource used to create, modify, or alter it.
• MeiTY, via its Draf t Amendments to IT Rules 2021 notified on 21st April 2026, has proposed that such information be labelled in a manner that “ensures continuous and clearly visible display of such label throughout the duration of the content, in a visual ” This requirement will further help distinguish SGI from real content.

Anti-Tampering Safeguards

Intermediaries must not enable the modification, suppression or removal of the SGI label or the permanent metadata, provenance mechanisms, and unique identifiers embedded for SGI identification. This ensures transparency and traceability and prevents circumvention of labelling obligations. Intermediaries should not offer functionalities such as “remove watermark” or “export without metadata” that would undermine SGI identification.

IV.         Additional Obligations for Significant Social Media Intermediaries

a)   User Declaration and Technical Verification

The amendments introduce a new ruleintroduce new a rule, which imposes enhanced obligations on Significant Social Media Intermediaries (“SSMIs”) in relation to SGI. Before allowing users to display, upload or publish information, an SSMI must:

• Obtain a User Declaration: Require users to declare whether the content is
• Deploy Technical Verification Measures: Deploy reasonable and appropriate technical measures (including automated tools) to verify the correctness of such declaration prior to publication, having regard to the nature, format, and source of information.
• Display Prominent Labels: Where confirmed as SGI (by declaration and/or technical verification), ensure the content is displayed with a clear and prominent label or notice indicating that it is synthetically

Notably, the verification obligation is explicit and mandatory; SSMIs cannot rely solely on user self- declaration but must deploy technical measures to verify user declarations prior to publication. This ensures stronger prevention of deception, impersonation and misuse of deepfakes on large platforms.

b)     Accountability for SSMI

Where an SSMI knowingly permits, promotes or fails to act upon SGI in contravention of the Rules, it shall be deemed to have failed to exercise due diligence under the IT Rules. This strengthens platform accountability in relation to unlawful SGI.

c)     Strengthened Technology-Based Measures

The amendments strengthen Technology-Based Measures as an obligation, moving away from an

“endeavour” based verbiage to a clearer, mandatory and proportionate obligation for SSMIs to deploy reasonable and appropriate technical measures, including automated tools or other suitable

mechanisms, to ensure effective due diligence.

V.          Accelerated Compliance Timelines

a) Reduced Grievance Redressal Timelines

The amendments significantly tighten compliance timelines across multiple provisions:

• General Grievance Resolution: Intermediaries must resolve grievances received from users within 7 days (reduced from the earlier 15 days).
• Special Categories Requiring Urgent Action: For grievances relating to requests for removal of or disabling access to deceptive or impersonation content, the timeline is reduced to 36 hours (from the earlier 72 hours).
• Nudity, Sexual Content, Morphed Content, and Impersonation: Intermediaries must remove or disable access to content relating to nudity, sexual acts, morphed content, or impersonation within 2 hours of receiving a complaint (reduced from the earlier 24 hours).
• Actual Knowledge from Authorized Officers: Upon receiving actual knowledge through an order of a court or a reasoned intimation from an authorized officer of the Appropriate Government or its agency, intermediaries must remove or disable access to unlawful information within 3

These reduced timelines reflect the regulatory recognition that harmful content, particularly SGI such as deepfakes, can spread virally within minutes and cause irreversible damage, including reputational harm, extortion, non-consensual intimate imagery, public order issues, misinformation and fraud.

VI.         User Accountability

a)  Intermediary Actions Against Violating Users

Where a user creates, uploads, publishes, transmits, shares or disseminates unlawful SGI or otherwise violates the Rules or terms, the intermediary is required to take expeditious and appropriate action. Such actions may include:

• Content Removal: Immediate removal of, or disabling access to, the unlawful SGI or
• Account Actions: Suspension or termination of the user account responsible for the violation (including prevention of further uploads), while preserving evidence such as logs and relevant information for investigation or legal proceedings.
• Disclosure to Authorities: Where required under applicable law, identification and disclosure of information relating to the violating user to the complainant or competent authority, in accordance with due process and legal requirements.

b)     User Liability for Violations

Users who create, generate, modify, alter, host, display, upload, publish, transmit, store, update, share or otherwise disseminate information in contravention of any law may be liable to penalty or punishment under the provisions of the Information Technology Act, 2000 (“IT Act”) or any other applicable law.

VII.          Preservation of Safe Harbor Protections Under Section 79 of the IT Act

A critical clarification in the amendments addresses intermediary concerns regarding the preservation of safe harbor protections under Section 79 of the IT Act. The Rules explicitly clarify that removal or disabling of access to any information (including SGI) by an intermediary in compliance with the Rules (including via reasonable technical measures such as automated tools) shall not amount to a violation of the conditions under Section 79 of the IT Act. This clarification is designed to encourage intermediaries to deploy technical measures and take proactive action against unlawful SGI without fear of losing their intermediary liability protections.

VIII.          Balancing Innovation and Regulation: Implications for the Digital Ecosystem

a)    Impact on Content Moderation Practices

The SGI framework fundamentally alters content moderation practices for intermediaries operating in India. The requirement to deploy reasonable and appropriate technical measures, including automated tools, to prevent unlawful SGI necessitates significant investment in detection technologies, content classification systems, and human oversight mechanisms.

Intermediaries must implement mechanisms for appropriate human oversight of measures deployed, including periodic review of any automated tools. The measures taken must be proportionate, having regard to the interests of free speech and expression, and the privacy of users.

b)     Fostering Responsible AI Innovation

The amendments aim to establish a regulatory framework that protects users while encouraging responsible innovation. By clearly delineating between prohibited SGI, permissible labelled SGI, and excluded routine uses, the framework seeks to provide clarity for businesses developing AI technologies while ensuring user protection.

The explicit recognition that SGI can deliver significant benefits such as innovation, accessibility and inclusive digital growth, when harnessed with robust safeguards, signals the regulatory intent to support India's digital economy and advance inclusive, safe, and responsible digital transformation.

c)     Challenges in Implementation and Enforcement

Several practical challenges emerge in implementing and enforcing these regulations:

• Technical Feasibility: The requirement to embed permanent metadata and unique identifiers “to the extent technically feasible” acknowledges current technological limitations in provenance tracking, but leaves room for interpretative disputes.
• Detection Accuracy: Automated tools for detecting SGI are evolving technologies with varying degrees of accuracy, raising concerns about false positives and over-censorship.
• User Declaration Verification: SSMIs face the operational challenge of verifying user declarations at scale, requiring sophisticated technical infrastructure.
• Cross-Border Compliance: For global platforms, harmonizing compliance with India's SGI framework alongside other jurisdictions' AI and content regulations presents complex operational

d)     Interplay with Existing Legal Frameworks

The SGI amendments build upon and strengthen the existing intermediary liability framework under the IT Rules, 2021.

SGI violations may trigger liability under multiple legal frameworks, including provisions of the IT Act, the Bharatiya Nyaya Sanhita, 2023, the Protection of Children from Sexual Offences Act, 2012, and other applicable laws. Where violations relate to the commission of offences that are mandatorily reportable, intermediaries have an obligation to report such offences to the appropriate authority.

IX.         Conclusion: Shift in regulating the impact of AI

The amendments to the IT Rules represent an important shift in India's approach to regulating AI.

The Government of India has codified its intent to ensure that the benefits of AI technologies are realised while protecting users from the serious harms associated with deepfakes and other forms of deceptive synthetic media.

The regulatory framework seeks to strike a careful balance, preserving space for innovation, creativity, accessibility, and legitimate uses of synthetic media technologies while establishing clear guardrails against misuse. The exclusions for routine editing, accessibility tools, and creative content demonstrate regulatory sophistication and acknowledgement of beneficial AI applications.

For intermediaries, social media platforms, content creators, and technology companies, the SGI framework is not optional. The amendments are operational law, with accelerated compliance timelines, stringent due diligence obligations, and clear enforcement consequences.

As India's digital economy continues to grow and as AI technologies become increasingly sophisticated and accessible, the SGI regulatory framework will likely evolve. Stakeholders should anticipate further clarifications, technical standards development, and potential regulatory guidance on implementation challenges.

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