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On July 31, 2026, the National Radio and Television Administration (NRTA) officially issued Order No. 16, the Measures for the Administration of the Development of Micro-Short Dramas, which takes effect on September 1, 2026. This is China’s first departmental regulation dedicated specifically to micro-short dramas. The new rules set out requirements for classified management, filing and public announcement, distribution licensing, content review, broadcasting management, labeling of AI-generated content, and overseas broadcasting.
This article examines the key issues that AI short drama companies should focus on under the new regulation.
（Source: National Radio and Television Administration (NRTA)）
I. Three-Tier Classified Management: How Should AI Short Dramas Be Categorized?
The new regulation divides micro-short dramas into three categories based on investment amount and subject matter, applying differentiated regulation:
| Category | Criteria | Regulatory Requirements |
|---|---|---|
| Category I | Relatively large investment amount, or involving special subject matters such as politics, military, diplomacy, national security, united front, ethnicity, religion, judiciary, public security, etc. | Filing and public announcement + content review + Micro-Short Drama Distribution License |
| Category II | General subject matter with relatively moderate investment | Filing and public announcement + content review + approval document from provincial radio and TV authorities by reference |
| Category III | General subject matter with relatively low investment | Pre-broadcast review by the broadcasting entity + program number labeling |
AI short drama companies must first clarify their content positioning. At present, most AI-generated short dramas have relatively low production costs, but this does not automatically mean they fall into Category III. Project classification still depends on a concrete assessment of investment amount, subject matter, and other factors. For Category II micro-short dramas, the new regulation also makes clear that provincial radio and TV authorities may formulate local implementation rules by reference to the filing and public announcement system for Category I micro-short dramas.
Legal Recommendations:
Prepare a list of existing and in-production projects, and classify them by investment amount, subject matter, production entity, production location, broadcasting platform, and domestic/overseas broadcasting. This will help identify the compliance path and time cost for each project. For AI short drama projects that plan to bring in foreign capital or involve co-production, it is especially important to clarify the regulatory classification at the project initiation stage, so as to avoid compliance issues that could affect cross-border capital flows or cooperation.
II. Special Rules for AI Short Dramas: Labeling Obligations, Content Red Lines, and Algorithm Governance
1. Labeling obligation: Article 34 of the new regulation expressly provides: “For micro-short dramas generated or produced using artificial intelligence technology, the production entity and the broadcasting entity shall comply with relevant national provisions and, in accordance with relevant rules, add a conspicuous notice label in each episode.”
2. Content red lines: Article 25 lists 11 prohibited categories. Micro-short dramas may not contain content that endangers national security or national unity, incites ethnic hatred, denigrates China’s excellent traditional culture, incites disruption of national religious policy, infringes on the lawful rights and interests or physical and mental health of minors, damages ecological and environmental protection, promotes obscenity, gambling, drug use, money worship, or extravagance, or depicts violence and terror.
3. Algorithm governance: “Addictive” features have also become a regulatory focus. Article 37 requires broadcasting entities to “regularly review, evaluate, and verify algorithm mechanisms,” give priority to recommending high-quality content, and refrain from using algorithm models that induce addiction or excessive consumption.
AI short dramas face “dual compliance” pressure: they must meet the general content standards for micro-short dramas and also satisfy the special disclosure requirements for AI-generated content. In practice, AI-generated historical figures and fictional plots can easily cross red lines such as “distorting history” or “desecrating heroes and martyrs.” Companies need to establish an AI content pre-review mechanism and cannot rely solely on technical review.
Legal Recommendations:
- Embed an “AI-generated” watermark or label during the final production stage to ensure the label is conspicuous.
- Establish a dual human + AI content review process, focusing on sensitive scenes involving history, ethnicity, religion, and minors.
- Retain full-chain evidence, including AI training data sources, generation parameters, and human modification records, for regulatory inspection.
（Source: Online Audio-Visual Program Review System）
III. Heavier Platform Responsibility: Stricter Review by Broadcasting Entities and Higher Market Entry Thresholds
The new regulation imposes strict primary responsibility on broadcasting entities:
- Before broadcasting Category I and Category II micro-short dramas, they must verify the Micro-Short Drama Distribution License or approval document.
- For Category III micro-short dramas, the broadcasting entity must perform content management duties, conduct pre-broadcast review, and label the program number.
- Establish an editor-in-chief content responsibility system and a full-process accountability and traceability mechanism for content safety.
- Establish a credit evaluation system for key accounts that disseminate micro-short dramas and subject them to focused management.
Due to the special nature of AI content generation, AI short dramas may face stricter requirements in the future regarding copyright proof, AI labeling, licenses, material authorization, and manual re-review. This may lead to longer review cycles, more supplementary document requests, and an increased risk of temporary removal. This means that content compliance costs for AI short drama companies will rise significantly.
Legal Recommendations:
- Communicate with major broadcasting platforms in advance to understand their internal review rules and special requirements for AI content.
- Introduce compliance assessment at the project planning stage to avoid sunk costs caused by failed review after production is completed.
- Consider voluntarily applying for Category I or Category II standards for some projects. Obtaining formal permission may actually give the project priority in platform recommendations.
IV. Intellectual Property and Data Compliance: Legal Risks in AI Short Drama Content
Article 10 of the new regulation clearly states that “intellectual property related to micro-short dramas is protected by law” and that “organizations and individuals engaged in micro-short drama activities shall enhance their awareness of intellectual property.”
AI short dramas face three major legal risks in this area:
- Training data compliance: Have the film and television materials, scripts, novels, images, and music used in AI model training been authorized?
- Ownership of generated content: Who owns the copyright in AI-generated scripts, characters, and images? For example, directly uploading screenshots of popular TV dramas, celebrity photos, or anime character images and asking AI to “generate by reference.” Even if the final result is not the original image, copyright and portrait rights risks cannot be excluded.
- Infringement of personality rights: If AI-generated character images or voices resemble real natural persons, this may trigger infringement of portrait rights or voice rights.
Legal Recommendations:
- Establish a mechanism for reviewing the lawful source of training data and retain evidence of the authorization chain.
- Conduct a “significant difference” review of AI-generated content to avoid high similarity with real persons or existing IP.
- Clearly agree with AI technology suppliers on the ownership of intellectual property in generated content and the allocation of liability for infringement.
V. Global Expansion Compliance: The “Dual Threshold” of Domestic Production and Overseas Broadcasting, and Global Layout
Article 8 of the new regulation states that China “supports the creation, production, and dissemination of export-oriented micro-short dramas, facilitates the participation of overseas principal creators in the creation of micro-short dramas, and supports the simultaneous domestic and overseas broadcasting of excellent micro-short dramas.” Article 52 provides that “micro-short dramas filmed within China for overseas broadcasting shall be subject to the relevant provisions of these Measures on filing and public announcement, review, and licensing.”
This legislative attitude of “supporting global expansion but requiring compliance first” deserves close attention. Although global expansion of AI short dramas is an industry hotspot, “domestic production and overseas broadcasting” still requires domestic filing and review procedures. Content that has not obtained domestic permission may face regulatory tracing even if it is broadcast only on overseas platforms.
A deeper issue is that different jurisdictions have vastly different regulatory frameworks for AI-generated content:
| Jurisdiction | Key Regulatory Requirements | Impact on AI Short Dramas |
|---|---|---|
| European Union | The AI Act classifies AI-generated content as subject to limited transparency obligations, requiring clear labeling of AI generation | AI system compliance assessment required |
| United States | Some states have enacted laws requiring AI content disclosure; at the federal level, rules mainly involve consumer protection, advertising, and misleading promotion | Clear AI-generated labeling in content to avoid misleading consumers |
| Southeast Asia | Standards vary by country; some countries have no dedicated legislation, but content review is tightening | Country-by-country assessment required; domestic version cannot simply be copied |
| Middle East | Strict review of religious and cultural content; AI-generated content may receive additional scrutiny | Local cultural compliance review must be conducted in advance |
If companies produce content only according to domestic standards, they may face secondary compliance or even removal risks after going overseas. In particular, the “AI-generated labeling” required by the new domestic rules is converging in direction with the transparency obligations of the EU AI Act and the disclosure requirements of some U.S. states, but there may be differences in label placement, wording, and technical implementation. A direct translation of the domestic version may not satisfy overseas requirements.
Legal Recommendations:
- Incorporate the AI content regulatory requirements of target markets into the script and production stages, rather than simply adding labels later.
- After completing domestic compliance review and obtaining permission, make localized compliance adjustments for different markets, rather than releasing one version globally.
- For companies planning to operate overseas businesses, it is necessary to simultaneously monitor the connection between the new domestic rules and overseas investment regulatory requirements.
（Source: CCTV.com）
Conclusion
The implementation of the Measures for the Administration of the Development of Micro-Short Dramas presents both difficulties and opportunities for AI short drama companies. The difficulties lie in rising compliance costs, stricter content review, and intensified algorithm governance; the extensive growth model will be difficult to sustain. The opportunities lie in the fact that compliant companies will obtain the “credit endorsement” of formal permission and gain a first-mover advantage in platform recommendations, capital connections, and global expansion.
For AI short drama companies intending to enter overseas markets, domestic compliance permission is not only a “passport” but may also become the credit foundation for negotiating with overseas platforms and obtaining copyright procurement or co-production opportunities. Only by front-loading compliance, actively adapting, and establishing a dual-track risk control system at home and abroad can AI short drama companies stand out in the industry’s development.
About the Author
Yu Yuting
Partner | NEO-ARK Law Firm
Lawyer Yu focuses on foreign-related litigation, cross-border disputes, commercial matters, and legal services for overseas individuals and businesses in China.
Email: [email protected]
About NEO-ARK Law Firm
NEO-ARK Law Firm provides legal services in foreign-related litigation, commercial disputes, family law, and cross-border legal matters, assisting both international and domestic clients throughout China.
