China Moves to Regulate AI Virtual Humans, Protect Personality Rights

3 min readSources: Lex Blog

China unveiled draft rules to regulate AI-driven digital virtual humans and safeguard personality rights.

Why it matters: This marks a pivotal advance in China's approach to AI governance, directly impacting digital identity rights and virtual human technologies. Legal professionals face new compliance challenges under emerging personality rights protections in a major jurisdiction.

  • On April 3, 2026, China's Cyberspace Administration released draft rules for digital virtual humans.
  • The measures require clear labeling of digital human content and explicit consent to use likeness or voice.
  • The draft prohibits virtual intimate relationships and manipulative spending prompts for minors.
  • Public consultation is open until May 6, 2026, with finalized regulation expected afterward.

China is accelerating efforts to address legal and ethical risks from AI-generated digital humans with new draft regulations released by the Cyberspace Administration of China (CAC) on April 3, 2026. The proposed 'Measures for the Management of Digital Virtual Human Information Services' create a distinct legal framework for regulating digital avatars, which are increasingly deployed in entertainment, marketing, and public service contexts.

  • Transparent labeling: All digital human content must be visibly marked—such as with 'Digital Human'—throughout display, reducing risks of deception or impersonation. (China Daily Asia)
  • Consent and personality rights: The draft rules require explicit consent before an individual's likeness, voice, or other personal data can be used for digital human creation, supporting personal information protection under Chinese civil law.
  • Protecting minors: Digital humans may not provide 'virtual intimate relationships' to users under 18 or induce excessive spending, aiming to safeguard minors’ wellbeing.
  • Content restrictions: Prohibition on content with sexual innuendo, violence, horror, or discrimination; entities must prevent such content from circulating online.

Du Cuilan, deputy director of the National Computer Network Emergency Response Technical Team/Coordination Center of China, highlighted key risks: “Digital humans are highly deceptive and realistic. There are significant risks of them being used to generate harmful content, spread rumors, incite crime, or maliciously induce consumption.”

The rules reflect growing concern as digital avatars blur lines between authentic and synthetic personas, raising possibilities for impersonation or personality rights violations. These proposed regulations reinforce legal boundaries for digital identity, and their adoption will set a significant precedent for AI governance worldwide.

The CAC is seeking public and industry input until May 6, 2026, after which details—including enforcement mechanisms—may be refined before finalization.

By the numbers:

  • April 3, 2026 — Draft regulations released by the Cyberspace Administration of China
  • May 6, 2026 — Public consultation period ends for feedback on the draft measures

Yes, but: Specific enforcement mechanisms and penalties remain undefined in the current draft.

What's next: Public feedback during the consultation period may shape the final rules expected after May 6, 2026.