Regulating synthetic realities: India’s IT Rules Amendment and the future of digital accountability
31 October 2025
In an era where artificial intelligence can conjure convincing replicas of faces, voices and entire personalities, the boundaries between truth and fabrication are blurring rapidly. The proliferation of deep fakes and AI-generated content has triggered legitimate concerns about privacy, defamation, misinformation, and personality rights. Recognizing this growing threat, the Ministry of Electronics and Information Technology (MeitY) has proposed amendments to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, marking India’s first regulatory step towards addressing synthetic media.
A definition for the AI age
The proposed amendments formally introduce the term “synthetically generated information”, defined as: “Information which is artificially or algorithmically created, generated, modified or altered using a computer resource, in a manner that such information reasonably appears to be authentic or true.”
This definition is pivotal. For the first time, Indian law explicitly recognises the category of AI-generated or manipulated content. It covers not only fabricated media created from scratch but also altered or modified material that simulates authenticity.
Traditionally, infringements arising from deepfakes or manipulated content were addressed through a patchwork of laws on privacy, defamation, and passing off. However, these frameworks were never designed to handle the speed, scale or sophistication of synthetic media. The new definition thus fills a crucial legal vacuum acknowledging the need for specific regulation to safeguard both individuals and institutions in the digital ecosystem.
Judicial momentum meets regulatory reform
The amendments build on momentum already created by Indian courts, particularly the Delhi High Court, which has been proactive in protecting personality rights in the digital age. In recent cases involving Aishwarya Rai Bachchan, Abhishek Bachchan, Anil Kapoor, Nagarjuna, Karan Johar, Akshay Kumar, Jackie Shroff (Jaikishan Kakubhai Saraf), Amitabh Bachchan, Aaradhya Bachchan, Suniel Shetty, Hritik Roshan, Rajnikanth (Shivaji Rao Gaikwad), Vishnu Manchu, Mohan Babu, Kumar Sanu, Asha Bhosle, Daler Mehndi, Ratan Tata, Sri Sri Ravi Shankar, Sadhguru Jaggi Vasudev, Ankur Warikoo and others, the High Court issued injunctions against unauthorized AI-generated or digitally manipulated content, recognising the real harm caused by synthetic impersonations.
These judicial interventions have set a clear tone: unauthorised digital cloning or AI-driven misrepresentation violates fundamental rights. The proposed amendments now provide procedural and regulatory muscle to reinforce that position.
Shifting responsibility: From reactive to proactive
Under Rule 3, which sets out intermediaries’ due diligence obligations, the amendments substantially expand responsibility for identifying and managing synthetic content. A new proviso clarifies that intermediaries acting in good faith to remove or disable access to synthetically generated information will not lose their safe-harbour protection under Section 79 of the IT Act. This strikes a vital balance empowering platform to act decisively while protecting them from accusations of bias or overreach.
Further, the introduction of Rule 3(3) heightens the compliance burden on intermediaries that enable or facilitate the creation or modification of information. Such platforms will now need to identify, label, and authenticate synthetically generated material by embedding unique metadata or identifiers, ensuring traceability across digital platforms.
In effect, the regime moves from a reactive complaint-based approach to a proactive accountability framework requiring intermediaries to anticipate and prevent harm before it occurs.
Social media giants in the spotlight
Significant Social Media Intermediaries (SSMIs) face even greater obligations under the proposed Rule 4(1)(a). They must now deploy pre-publication safeguards to detect and label synthetically generated content.
Before publication, users will be required to declare whether their content is synthetic. Platforms must use automated tools to verify these declarations and display a prominent label or notice identifying synthetic media.
If a platform knowingly permits or fails to act against such content, it will be deemed to have breached its due diligence obligations jeopardizing its safe-harbour immunity. This marks a paradigm shift in how India expects large platforms to manage manipulated media, placing responsibility squarely at the gatekeeper level.
Strengthening enforcement and traceability
For rights holders and regulators, the amendments promise stronger enforcement mechanisms. The obligation to label and trace synthetically generated content will aid in swift identification of manipulated media, facilitating compliance with judicial orders such as takedowns or injunctions against impersonation and defamation.
However, these obligations could also create new tensions. The reliance on automated detection tools may lead to over-compliance or algorithmic bias, where legitimate satire, parody, or creative content is wrongfully flagged or removed. Balancing regulatory intent with free expression will require careful calibration in implementation.
Balancing innovation with accountability
Synthetic media itself is not inherently harmful. When responsibly used, AI-generated imagery and voices can drive innovation in entertainment, accessibility, education, and research. The challenge lies in distinguishing innovation from impersonation.
The proposed IT Rules amendments acknowledge this nuance. By introducing obligations that focus on labelling, transparency, and traceability, rather than outright prohibition, they attempt to regulate without stifling creativity. This is a crucial distinction in a country that is both a major creator and consumer of digital content.
A turning point for digital governance
Ultimately, the amendments reflect India’s growing recognition that digital integrity the ability to trust what one sees and hears online is a societal imperative. As technology evolves faster than regulation, such frameworks are essential to restore accountability in a fragmented information ecosystem.
While the true test will lie in implementation, the proposed changes represent a forward-looking and balanced step. They harmonise judicial concern with regulatory foresight, placing India among the few jurisdictions taking active measures to confront the risks of synthetic media.
If enacted, these amendments could well mark the beginning of India’s synthetic media governance era a chapter defined by responsibility, transparency, and an insistence that digital innovation must always coexist with ethical restraint.
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