Recently, the first domestic AI-generated TV series successfully premiered on satellite television, sending shockwaves through the industry. This series, which involved artificial intelligence throughout the entire process of scriptwriting, visual generation, and even voice acting and scoring, received broadcast approval, yet it also exposed real-world issues in the current regulatory framework, including vague review standards for AI content and unclear classifications. Experts have called for more refined classification and review standards, but from a legal practice perspective, AI-driven series face far more hurdles than just review standards. Copyright ownership, content compliance, and data security—each of these areas could become a flashpoint for legal risk.

What gaps exist in current legal regulation regarding the satellite broadcast of AI-generated TV series?

China's regulation of radio, television, and online audiovisual content is primarily based on the "Regulations on the Administration of Radio and Television," the "Provisions on the Administration of Internet Audiovisual Program Services," and the "General Rules for Content Review of Online Audiovisual Programs." When these regulations and industry standards were formulated, AI-generated content had not yet entered the public eye on a large scale. As a result, questions such as "at what level of AI involvement in creation does special labeling become necessary" and "whether review standards for AI-generated content should be consistent with those for traditional content" have not been clearly answered.

Currently, AI series broadcast on satellite TV can only follow the review process of traditional dramas, with content reviewed by the radio and television authorities in accordance with the "Regulations on TV Drama Content Management." However, AI-generated content has its own particularities: first, the generation process relies heavily on algorithms and training data, which may contain data bias or embedded inappropriate content; second, content generation is unpredictable, and the same script can produce vastly different visuals and dialogue under different parameters. This means that even if a review is passed before broadcast, new compliance issues may still arise during subsequent broadcasting.

From a legal practice perspective, the direct consequence of this regulatory gap is that film and television companies cannot accurately predict approval risks when investing in AI-produced series. The same project may receive completely different review outcomes depending on how reviewers interpret AI content. This uncertainty poses a huge commercial risk for film and television projects that often involve investments of tens of millions.

How is copyright ownership of AI-generated content legally determined?

The most core legal dispute regarding AI TV series lies in the issue of copyright ownership. China's Copyright Law stipulates that copyright belongs to the author, and "author" refers to the natural person, legal entity, or other organization that creates the work. Under the current legal framework, AI itself cannot become a copyright holder. So, to whom do the scripts, visuals, and music generated by AI actually belong?

In judicial practice, the current mainstream view is the "tool theory"—that is, AI is regarded as a creative tool, and the copyright belongs to the natural person or legal entity that makes a substantive contribution to the generated content. In a copyright infringement case involving AI-generated images concluded by the Beijing Internet Court in 2023, it was explicitly determined that if AI-generated content reflects the personalized arrangement and choices of a human, it can constitute a work, and the copyright belongs to the user.

But an AI drama series is far more complex than a single image. A series involves multiple stages such as script, storyboard, visuals, music, and voice acting, each of which may be completed independently by AI or through human-AI collaboration. If the script is independently generated by AI and the director only makes simple modifications, how is "substantial contribution" determined? If AI learns and generates based on unauthorized copyrighted material, how should that be handled? There are no direct answers to these questions in current law.

For film and television companies, the safest approach is to clearly define the copyright ownership of AI-generated content through contracts before project initiation. At the same time, compliance reviews should be conducted on the sources of AI training data to avoid infringement lawsuits arising from generated content due to infringing training data.

AI Drama Series Content Review and Data Compliance: How to Guard Against Dual Risks?

In addition to copyright, AI series also face the dual risks of content review and data compliance.

In terms of content review, AI-generated content may contain unexamined sensitive information or inappropriate expressions. Traditional TV series can be strictly controlled through script review, sample episode inspection, and other stages, but AI-generated content is dynamic and unpredictable, making review more difficult. Lawyers suggest that production companies should implement technical filtering mechanisms in the AI generation process to monitor and intercept generated content in real time, while also strengthening manual review in post-production to ensure that broadcast content complies with the requirements of the "General Rules for Content Review of Online Audiovisual Programs."

In terms of data compliance, AI training data may involve sensitive information such as personal information and private data. According to the Personal Information Protection Law, processing personal information requires obtaining individual consent and must follow the principle of minimal necessity. If AI training data contains unauthorized personal information, it may face administrative penalties. In addition, if AI-generated content involves deep synthesis technology, it is also necessary to comply with the Provisions on the Administration of Deep Synthesis of Internet Information Services, and clearly label the generated content.

The "Measures for the Labeling of AI-Generated Synthetic Content," which took effect in January 2024, explicitly require that AI-generated content be labeled prominently in appropriate locations to avoid public confusion. This regulation imposes new compliance requirements for AI-produced TV series airing on satellite channels—not only must "AI-generated" be indicated in the opening and closing credits, but it should also be marked in promotional materials and program descriptions.

How can film and television companies address compliance challenges in AI-generated series? A lawyer offers four suggestions.

Facing the legal uncertainties surrounding AI TV series, film and television companies should not simply wait for policies to improve, but instead proactively build compliance systems. Based on our practical experience, we recommend addressing this from the following four aspects:

First, establish a whole-process compliance review mechanism for AI content. Introduce legal review from the scriptwriting stage, conduct compliance assessments of AI-generated scripts, visuals, and other content, and promptly identify and correct potential risks.

Second, improve the intellectual property clauses in contracts. When signing agreements with AI technology providers, screenwriters, directors, and other parties, clearly stipulate the ownership of copyright in AI-generated content, the scope of use, and the assumption of infringement liability, so as to avoid subsequent disputes.

Third, ensure the legality of training data sources. Conduct compliance reviews of AI training data to ensure that it does not infringe on others' copyrights, does not contain personal information or privacy data, and maintain complete records of data sources.

Fourth, closely monitor policy developments and adjust compliance strategies in a timely manner. AI content regulation policies are being rapidly refined, and film companies should remain sensitive to policy changes, and when necessary, hire professional lawyers to provide compliance consulting services.

AI-produced TV series airing on satellite channels is a new trend in the content industry, but the legal risks cannot be overlooked. Before regulatory standards are clarified, film and television companies can only navigate this technological transformation steadily through professional legal compliance management. Guangdong Zhiming Law Firm has long focused on legal affairs concerning cultural media and artificial intelligence, and has provided specialized AI content compliance services to multiple film and television companies, helping clients strike a balance between innovation and compliance. If you encounter legal issues in the creation, broadcast, or investment of AI-produced TV series, please feel free to contact us at any time, and we will provide you with professional legal support.