Case 04: Deepfake Generator
Deepfake Generator: is it legal in the EU, the United States and China?
The system on trial: synthetic media tool. The same product meets three legal realities. Each verdict below is an editorial summary of the instruments cited under it, so every claim can be checked against the official text in one click.
EU: TRANSPARENCY DUTY. US: LIGHT-TOUCH. CN: HEAVILY REGULATED
Deepfake Generator: how does the European Union treat it?
TRANSPARENCY DUTY. Label it, machine-readably. Providers embed machine-readable marking (Art. 50(2)); deployers visibly disclose deepfakes (Art. 50(4)), with a relaxed disclosure mode for artistic and satirical works.
TRANSPARENCY DUTY means: Allowed, provided users are told AI is involved and content is labeled.
Source: Art. 50(2): AI Act: machine-readable marking; Art. 50(4): AI Act: deepfake disclosure
The trapdoor: PROHIBITED
From 2 Dec 2026, systems designed for non-consensual intimate imagery or CSAM become prohibited: a new Art. 5 category added by Reg. 2026/1744.
Deepfake Generator: how does the United States treat it?
LIGHT-TOUCH (TOOL) and PROHIBITED (OUTPUTS). No law licenses the tool; liability hits the misuse. The TAKE IT DOWN Act criminalizes nonconsensual intimate deepfakes and the FTC enforces 48-hour platform takedowns ($53,088/violation); ~20 states restrict election deepfakes; the FCC killed AI-voice robocalls; California watermarking starts 2 Aug 2026.
LIGHT-TOUCH means: No dedicated AI law, only general consumer/deception rules apply.
Source: Pub. L. 119-12: TAKE IT DOWN Act; FCC TCPA: FCC AI-voice robocall ruling
Deepfake Generator: how does China treat it?
HEAVILY REGULATED. The world's most detailed synthetic-media regime. Algorithm filing, security assessment, real-name verification, consent of impersonated persons, prominent labeling and GB 45438-2025 metadata; tampering is prohibited and the Criminal Law provides the teeth.
HEAVILY REGULATED means: Legal, but gated by conformity, licensing, oversight and documentation duties.
Source: Deep Synthesis: Deep Synthesis Provisions (Jan 2023); GB 45438-2025: Mandatory AI-content labeling standard
The other 5 cases on the board
- AI Hiring Tool: legal in the EU, the US and China?CV screening & candidate ranking. EU: HEAVILY REGULATED. US: HEAVILY REGULATED. CN: MOSTLY UNREGULATED.
- LLM Chatbot: legal in the EU, the US and China?general-purpose customer service. EU: TRANSPARENCY DUTY. US: LIGHT-TOUCH. CN: LICENSED: FILING REQUIRED.
- Medical Diagnostic AI: legal in the EU, the US and China?AI-driven diagnostic device. EU: HEAVILY REGULATED. US: HEAVILY REGULATED. CN: LICENSED: FILING REQUIRED.
- Credit Scoring AI: legal in the EU, the US and China?automated creditworthiness. EU: HEAVILY REGULATED. US: HEAVILY REGULATED. CN: HEAVILY REGULATED.
- Police Live Facial Recognition: legal in the EU, the US and China?real-time biometric ID in public. EU: PROHIBITED. US: MOSTLY UNREGULATED. CN: HEAVILY REGULATED.
Read the regimes behind these verdicts
- The three regime dossiers explain why European Union, United States and China reach different answers about the same product.
- The Framework Explorer holds every instrument cited on this page, each with its own page, status, provisions and sources.
- Open this case on the interactive board to see the three stamps land side by side.
- The EU AI Act Explorer serves the text of Regulation (EU) 2024/1689 itself, one page per provision.
Knowing the verdict is step one. Passing the assessment is the job.
The programs teach the work that follows: classification calls, conformity assessment, filings, documentation, and the judgment to defend every decision.
VERIFIED 29 JUL 2026. The verdicts are editorial summaries of the instruments cited above, not rulings. Study aid, not legal advice: the official texts are always authoritative.