CyberPeace Outlook on the 2025 Amendments to the IT Intermediary Guidelines 2021
Introduction: Reasons Why These Amendments Have Been Suggested.
The suggested changes in the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, are the much-needed regulatory reaction to the blistering emergence of synthetic information and deepfakes. These reforms are due to the pressing necessity to govern risks within the digital ecosystem as opposed to regular reformation.
The Emergence of the Digital Menace
Generative AI tools have also facilitated the generation of very realistic images, videos, audio, and text in recent years. Such artificial media have been abused to portray people in situations they are not in or in statements they have never said. The market size is expected to have a compound annual growth rate(CAGR) from 2025 to 2031 of 37.57%, resulting in a market volume of US$400.00 bn by 2031. Therefore, tight regulatory controls are necessary to curb a high prevalence of harm in the Indian digital world.
The Gap in Law and Institution
None of the IT Rules, 2021, clearly addressed synthetic content. Although the Information Technology Act, 2000 dealt with identity theft, impersonation and violation of privacy, the intermediaries were not explicitly obligated on artificial media. This left a loophole in enforcement, particularly since AI-generated content might get around the old system of moderation. These amendments bring India closer to the international standards, including the EU AI Act, which requires transparency and labelling of AI-driven content. India addresses such requirements and adapts to local constitutional and digital ecosystem needs.
II. Explanation of the Amendments
The amendments of 2025 present five alternative changes in the current IT Rules framework, which address various areas of synthetic media regulation.
A. Definitional Clarification: Synthetic Generation of Information Introduction.
Rule 2(1)(wa) Amendment:
The amendments provide an all-inclusive definition of what is meant by “synthetically generated information” as information, which is created, or produced, changed or distorted with the use of a computer resource, in a way that such information can reasonably be perceived to be genuine. This definition is intentionally broad and is not limited to deepfakes in the strict sense but to any artificial media that has gone through algorithmic manipulation in order to have a semblance of authenticity.
Expansion of Legal Scope:
Rule 2(1A) also makes it clear that any mention of information in the context of unlawful acts, namely, including categories listed in Rule 3(1)(b), Rule 3(1)(d), Rule 4(2), and Rule 4(4), should be understood to mean synthetically generated information. This is a pivotal interpretative protection that does not allow intermediaries to purport that synthetic versions of illegal material are not under the control of the regulation since they are algorithmic creations and not descriptions of what actually occurred.
B. Safe Harbour Protection and Content Removal Requirements
Amendment, rule 3(1)(b)- Safe Harbour Clarification:
The amendments add a certain proviso to the Rule (3) (1)(b) that explains a deletion or facilitation of access of synthetically produced information (or any information falling within specified categories) which the intermediaries have made in good faith as part of reasonable endeavours or at the receipt of a complaint shall not be considered a breach of the Section 79(2) (a) or (b) of the Information Technology Act, 2000. This coverage is relevant especially since it insures the intermediaries against liability in situations where they censor the synthetic contents in advance of a court ruling or governmental warnings.
C. Labelling and Metadata Requirements that are mandatory on Intermediaries that enable the creation of synthetic content
The amendments establish a new framework of due diligence in Rule 3(3) on the case of intermediaries that offer tools to generate, modify, or alter the synthetically generated information. Two fundamental requirements are laid down.
- The generated information must be prominently labelled or embedded with a permanent, unique metadata or identifier. The label or metadata must be:
- Visibly displayed or made audible in a prominent manner on or within that synthetically generated information.
- It should cover at least 10% of the surface of the visual display or, in the case of audio content, during the initial 10% of its duration.
- It can be used to immediately identify that such information is synthetically generated information which has been created, generated, modified, or altered using the computer resource of the intermediary.
- The intermediary in clause (a) shall not enable modification, suppression or removal of such label, permanent unique metadata or identifier, by whatever name called.
D. Important Social Media Intermediaries- Pre-Publication Checking Responsibilities
The amendments present a three-step verification mechanism, under Rule 4(1A), to Significant Social Media Intermediaries (SSMIs), which enables displaying, uploading or publishing on its computer resource before such display, uploading, or publication has to follow three steps.
Step 1- User Declaration: It should compel the users to indicate whether the materials they are posting are synthetically created. This puts the first burden on users.
Step 2-Technical Verification: To ensure that the user is truly valid, the SSMIs need to provide reasonable technical means, such as automated tools or other applications. This duty is contextual and would be based on the nature, format and source of content. It does not allow intermediaries to escape when it is known that not every type of content can be verified using the same standards.
Step 3- Prominent Labelling: In case the synthetic origin is verified by user declaration or technical verification, SSMIs should have a notice or label that is prominently displayed to be seen by users before publication.
The amendments provide a better system of accountability and set that intermediaries will be found to have failed due diligence in a case where it is established that they either knowingly permitted, encouraged or otherwise failed to act on synthetically produced information in contravention of these requirements. This brings in an aspect of knowledge, and intermediaries cannot use accidental errors as an excuse for non-compliance.
An explanation clause makes it clear that SSMIs should also make reasonable and proportionate technical measures to check user declarations and keep no synthetic content published without adequate declaration or labelling. This eliminates confusion on the role of the intermediaries with respect to making declarations.
III. Attributes of The Amendment Framework
- Precision in Balancing Innovation and Accountability.
The amendments have commendably balanced two extreme regulatory postures by neither prohibiting nor allowing the synthetic media to run out of control. It has recognised the legitimate use of synthetic media creation in entertainment, education, research and artistic expression by adopting a transparent and traceable mandate that preserves innovation while ensuring accountability.
- Overt Acceptance of the Intermediary Liability and Reverse Onus of Knowledge
Rule 4(1A) gives a highly significant deeming rule; in cases where the intermediary permits or refrains from acting with respect to the synthetic content knowing that the rules are violated, it will be considered as having failed to comply with the due diligence provisions. This description closes any loopholes in unscrupulous supervision where intermediaries can be able to argue that they did so. Standard of scienter promotes material investment in the detection devices and censor mechanisms that have been in place to offer security to the platforms that have sound systems, albeit the fact that the tools fail to capture violations at times.
- Clarity Through Definition and Interpretive Guidance
The cautious definition of the term “synthetically generated information” and the guidance that is provided in Rule 2(1A) is an admirable attempt to solve confusion in the previous regulatory framework. Instead of having to go through conflicting case law or regulatory direction, the amendments give specific definitional limits. The purposefully broad formulation (artificially or algorithmically created, generated, modified or altered) makes sure that the framework is not avoided by semantic games over what is considered to be a real synthetic content versus a slight algorithmic alteration.
- Insurance of non-accountability but encourages preventative moderation
The safe harbour clarification of the Rule 3(1)(b) amendment clearly safeguards the intermediaries who voluntarily dismiss the synthetic content without a court order or government notification. It is an important incentive scheme that prompts platforms to implement sound self-regulation measures. In the absence of such protection, platforms may also make rational decisions to stay in a passive stance of compliance, only deleting content under the pressure of an external authority, thus making them more effective in keeping users safe against dangerous synthetic media.
IV. Conclusion
The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules 2025 suggest a structured, transparent, and accountable execution of curbing the rising predicaments of synthetic media and deepfakes. The amendments deal with the regulatory and interpretative gaps that have always existed in determining what should be considered as synthetically generated information, the intermediary liabilities and the mandatory labelling and metadata requirement. Safe-harbour protection will encourage the moderation proactively, and a scienter-based liability rule will not permit the intermediaries to escape liability when they are aware of the non-compliance but tolerate such non-compliance. The idea to introduce pre-publication verification of Significant Social Media Intermediaries adds the responsibility to users and due diligence to the platform. Overall, the amendments provide a reasonable balance between innovation and regulation, make the process more open with its proper definitions, promote responsible conduct on the platform and transform India and the new standards in the sphere of synthetic media regulation. They collaborate to enhance the verisimilitude, defence of the users, and visibility of the systems of the digital ecosystem of India.
V. References
2. https://www.statista.com/outlook/tmo/artificial-intelligence/generative-ai/worldwide
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Introduction
The Indian Cabinet has approved a comprehensive national-level IndiaAI Mission with a budget outlay ofRs.10,371.92 crore. The mission aims to strengthen the Indian AI innovation ecosystem by democratizing computing access, improving data quality, developing indigenous AI capabilities, attracting top AI talent, enabling industry collaboration, providing startup risk capital, ensuring socially-impactful A projects, and bolstering ethical AI. The mission will be implemented by the'IndiaAI' Independent Business Division (IBD) under the Digital India Corporation (DIC) and consists of several components such as IndiaAI Compute Capacity, IndiaAI Innovation Centre (IAIC), IndiaAI Datasets Platform, India AI Application Development Initiative, IndiaAI Future Skills, IndiaAI Startup Financing, and Safe & Trusted AI over the next 5 years.
This financial outlay is intended to befulfilled through a public-private partnership model, to ensure a structured implementation of the IndiaAI Mission. The main objective is to create and nurture an ecosystem for India’s AI innovation. This mission is intended to act as a catalyst for shaping the future of AI for India and the world. AI has the potential to become an active enabler of the digital economy and the Indian government aims to harness its full potential to benefit its citizens and drive the growth of its economy.
Key Objectives of India's AI Mission
● With the advancements in data collection, processing and computational power, intelligent systems can be deployed in varied tasks and decision-making to enable better connectivity and enhance productivity.
● India’s AI Mission will concentrate on benefiting India and addressing societal needs in primary areas of healthcare, education, agriculture, smart cities and infrastructure, including smart mobility and transportation.
● This mission will work with extensive academia-industry interactions to ensure the development of core research capability at the national level. This initiative will involve international collaborations and efforts to advance technological frontiers by generating new knowledge and developing and implementing innovative applications.
The strategies developed for implementing the IndiaAI Mission are via Public-Private Partnerships, Skilling initiatives and AI Policy and Regulation. An example of the work towards the public-private partnership is the pre-bid meeting that the IT Ministry hosted on 29th August2024, which saw industrial participation from Nvidia, Intel, AMD, Qualcomm, Microsoft Azure, AWS, Google Cloud and Palo Alto Networks.
Components of IndiaAI Mission
The IndiaAI Compute Capacity: The IndiaAI Compute pillar will build a high-end scalable AI computing ecosystem to cater to India's rapidly expanding AI start-ups and research ecosystem. The ecosystem will comprise AI compute infrastructure of 10,000 or more GPUs, built through public-private partnerships. An AI marketplace will offer AI as a service and pre-trained models to AI innovators.
The IndiaAI Innovation Centre will undertake the development and deployment of indigenous Large Multimodal Models (LMMs) and domain-specific foundational models in critical sectors. The IndiaAI Datasets Platform will streamline access to quality on-personal datasets for AI innovation.
The IndiaAI Future Skills pillar will mitigate barriers to entry into AI programs and increase AI courses in undergraduate, master-level, and Ph.D. programs. Data and AI Labs will be set up in Tier 2 and Tier 3 cities across India to impart foundational-level courses.
The IndiaAI Startup Financing pillar will support and accelerate deep-tech AI startups, providing streamlined access to funding for futuristic AI projects.
The Safe & Trusted AI pillar will enable the implementation of responsible AI projects and the development of indigenous tools and frameworks, self-assessment check lists for innovators, and other guidelines and governance frameworks by recognising the need for adequate guardrails to advance the responsible development, deployment, and adoption of AI.
CyberPeace Considerations for the IndiaAI Mission
● Data privacy and security are paramount as emerging privacy instruments aim to ensure ethical AI use. Addressing bias and fairness in AI remains a significant challenge, especially with poor-quality or tampered datasets that can lead to flawed decision-making, posing risks to fairness, privacy, and security.
● Geopolitical tensions and export control regulations restrict access to cutting-edge AI technologies and critical hardware, delaying progress and impacting data security. In India, where multilingualism and regional diversity are key characteristics, the unavailability of large, clean, and labeled datasets in Indic languages hampers the development of fair and robust AI models suited to the local context.
● Infrastructure and accessibility pose additional hurdles in India’s AI development. The country faces challenges in building computing capacity, with delays in procuring essential hardware, such as GPUs like Nvidia’s A100 chip, hindering businesses, particularly smaller firms. AI development relies heavily on robust cloud computing infrastructure, which remains in its infancy in India. While initiatives like AIRAWAT signal progress, significant gaps persist in scaling AI infrastructure. Furthermore, the scarcity of skilled AI professionals is a pressing concern, alongside the high costs of implementing AI in industries like manufacturing. Finally, the growing computational demands of AI lead to increased energy consumption and environmental impact, raising concerns about balancing AI growth with sustainable practices.
Conclusion
We advocate for ethical and responsible AI development adoption to ensure ethical usage, safeguard privacy, and promote transparency. By setting clear guidelines and standards, the nation would be able to harness AI's potential while mitigating risks and fostering trust. The IndiaAI Mission will propel innovation, build domestic capacities, create highly-skilled employment opportunities, and demonstrate how transformative technology can be used for social good and enhance global competitiveness.
References
● https://pib.gov.in/PressReleasePage.aspx?PRID=2012375
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Introduction
On the precipice of a new domain of existence, the metaverse emerges as a digital cosmos, an expanse where the horizon is not sky, but a limitless scope for innovation and imagination. It is a sophisticated fabric woven from the threads of social interaction, leisure, and an accelerated pace of technological progression. This new reality, a virtual landscape stretching beyond the mundane encumbrances of terrestrial life, heralds an evolutionary leap where the laws of physics yield to the boundless potential inherent in our creativity. Yet, the dawn of such a frontier does not escape the spectre of an age-old adversary—financial crime—the shadow that grows in tandem with newfound opportunity, seeping into the metaverse, where crypto-assets are no longer just an alternative but the currency du jour, dazzling beacons for both legitimate pioneers and shades of illicit intent.
The metaverse, by virtue of its design, is a canvas for the digital repaint of society—a three-dimensional realm where the lines between immersive experiences and entertainment blur, intertwining with surreal intimacy within this virtual microcosm. Donning headsets like armor against the banal, individuals become avatars; digital proxies that acquire the ability to move, speak, and perform an array of actions with an ease unattainable in the physical world. Within this alternative reality, users navigate digital topographies, with experiences ranging from shopping in pixelated arcades to collaborating in virtual offices; from witnessing concerts that defy sensory limitations to constructing abodes and palaces from mere codes and clicks—an act of creation no longer beholden to physicality but to the breadth of one's ingenuity.
The Crypto Assets
The lifeblood of this virtual economy pulsates through crypto-assets. These digital tokens represent value or rights held on distributed ledgers—a technology like blockchain, which serves as both a vault and a transparent tapestry, chronicling the pathways of each digital asset. To hop onto the carousel of this economy requires a digital wallet—a storeroom and a gateway for acquisition and trade of these virtual valuables. Cryptocurrencies, with NFTs—Non-fungible Tokens—have accelerated from obscure digital curios to precious artifacts. According to blockchain analytics firm Elliptic, an astonishing figure surpassing US$100 million in NFTs were usurped between July 2021 and July 2022. This rampant heist underlines their captivating allure for virtual certificates. Empowers do not just capture art, music, and gaming, but embody their very soul.
Yet, as the metaverse burgeons, so does the complexity and diversity of financial transgressions. From phishing to sophisticated fraud schemes, criminals craft insidious simulacrums of legitimate havens, aiming to drain the crypto-assets of the unwary. In the preceding year, a daunting figure rose to prominence—the vanishing of US$14 billion worth of crypto-assets, lost to the abyss of deception and duplicity. Hence, social engineering emerges from the shadows, a sort of digital chicanery that preys not upon weaknesses of the system, but upon the psychological vulnerabilities of its users—scammers adorned in the guise of authenticity, extracting trust and assets with Machiavellian precision.
The New Wave of Fincrimes
Extending their tentacles further, perpetrators of cybercrime exploit code vulnerabilities, engage in wash trading, obscuring the trails of money laundering, meander through sanctions evasion, and even dare to fund activities that send ripples of terror across the physical and virtual divide. The intricacies of smart contracts and the decentralized nature of these worlds, designed to be bastions of innovation, morph into paths paved for misuse and exploitation. The openness of blockchain transactions, the transparency that should act as a deterrent, becomes a paradox, a double-edged sword for the law enforcement agencies tasked with delineating the networks of faceless adversaries.
Addressing financial crime in the metaverse is Herculean labour, requiring an orchestra of efforts—harmonious, synchronised—from individual users to mammoth corporations, from astute policymakers to vigilant law enforcement bodies. Users must furnish themselves with critical awareness, fortifying their minds against the siren calls that beckon impetuous decisions, spurred by the anxiety of falling behind. Enterprises, the architects and custodians of this digital realm, are impelled to collaborate with security specialists, to probe their constructs for weak seams, and to reinforce their bulwarks against the sieges of cyber onslaughts. Policymakers venture onto the tightrope walk, balancing the impetus for innovation against the gravitas of robust safeguards—a conundrum played out on the global stage, as epitomised by the European Union's strides to forge cohesive frameworks to safeguard this new vessel of human endeavour.
The Austrian Example
Consider the case of Austria, where the tapestry of laws entwining crypto-assets spans a gamut of criminal offences, from data breaches to the complex webs of money laundering and the financing of dark enterprises. Users and corporations alike must become cartographers of local legislation, charting their ventures and vigilances within the volatile seas of the metaverse.
Upon the sands of this virtual frontier, we must not forget: that the metaverse is more than a hive of bits and bandwidth. It crystallises our collective dreams, echoes our unspoken fears, and reflects the range of our ambitions and failings. It stands as a citadel where the ever-evolving quest for progress should never stray from the compass of ethical pursuit. The cross-pollination of best practices, and the solidarity of international collaboration, are not simply tactics—they are imperatives engraved with the moral codes of stewardship, guiding us to preserve the unblemished spirit of the metaverse.
Conclusion
The clarion call of the metaverse invites us to venture into its boundless expanse, to savour its gifts of connection and innovation. Yet, on this odyssey through the pixelated constellations, we harness vigilance as our star chart, mindful of the mirage of morality that can obfuscate and lead astray. In our collective pursuit to curtail financial crime, we deploy our most formidable resource—our unity—conjuring a bastion for human ingenuity and integrity. In this, we ensure that the metaverse remains a beacon of awe, safeguarded against the shadows of transgression, and celebrated as a testament to our shared aspiration to venture beyond the realm of the possible, into the extraordinary.
References
- https://www.wolftheiss.com/insights/financial-crime-in-the-metaverse-is-real/
- https://gnet-research.org/2023/08/16/meta-terror-the-threats-and-challenges-of-the-metaverse/
- https://shuftipro.com/blog/the-rising-concern-of-financial-crimes-in-the-metaverse-aml-screening-as-a-solution/
Introduction
Indian Cybercrime Coordination Centre (I4C) was established by the Ministry of Home Affairs (MHA) to provide a framework for law enforcement agencies (LEAs) to deal with cybercrime in a coordinated and comprehensive manner. The Indian Ministry of Home Affairs approved a scheme for the establishment of the Indian Cyber Crime Coordination Centre (I4C) in October 2018. I4C is actively working towards initiatives to combat the emerging threats in cyberspace and it has become a strong pillar of India’s cyber security and cybercrime prevention. The ‘National Cyber Crime Reporting Portal’ equipped with a 24x7 helpline number 1930, is one of the key components of the I4C.
On 10 September 2024, I4Ccelebrated its foundation day for the first time at Vigyan Bhawan, New Delhi. This celebration marked a major milestone in India’s efforts against cybercrimes and in enhancing its cybersecurity infrastructure. Union Home Minister and Minister of Cooperation, Shri Amit Shah, launched key initiatives aimed at strengthening the country’s cybersecurity landscape.
Launch of Key Initiatives to Strengthen Cybersecurity
- Cyber Fraud Mitigation Centre (CFMC): As a product of Prime Minister Shri Narendra Modi’s vision, the Cyber Fraud Mitigation Centre (CFMC), was incorporated to bring together banks, financial institutions, telecom companies, Internet Service Providers, and law enforcement agencies on a single platform to tackle online financial crimes efficiently. This integrated approach is expected to minimise the time required to streamline operations and to track and neutralise cyber fraud.
- Cyber Commando: The Cyber Commandos Program is an initiative in which a specialised wing of trained Cyber Commandos will be established in states, Union Territories, and Central Police Organizations. These commandos will work to secure the nation’s digital space and counter rising cyber threats. They will form the first line of defence in safeguarding India from the growing cyber threats.
- Samanvay Platform: The Samanvay platform is a web-based Joint Cybercrime Investigation Facility System that was introduced as a one-stop data repository for cybercrime. It facilitates cybercrime mapping, data analytics, and cooperation among law enforcement agencies across the country. This will play a pivotal role in fostering collaborations in combating cybercrimes. Mr. Shah recognised the Samanvay platform as a crucial step in fostering data sharing and collaboration. He called for a shift from the “need to know” principle to a “duty to share” mindset in dealing with cyber threats. The Samanvay platform will serve as India’s first shared data repository, significantly enhancing the country’s cybercrime response.
- Suspect Registry: The Suspect Registry Portal is a national-level platform that has been designed to track cybercriminals. The portal registry will be connected to the National Cybercrime Reporting Portal (NCRP) which aims to help banks, financial intermediaries, and law enforcement agencies strengthen fraud risk management. The initiative is expected to improve the real-time tracking of cyber suspects, preventing repeat offences and improving fraud detection mechanisms.
Rising Digitalization: Prioritizing Cybersecurity
The number of internet users in India has grown from 25 crores in 2014 to 95 crores in 2024, accompanied by a 78-foldincrease in data consumption. This growth is echoed in the number of growing cybersecurity challenges in the digital era. With the rise of digital transactions through Jan Dhan accounts, Rupay debit cards, and UPI systems, Shri Shah underscored the growing threat of digital fraud. He emphasised the need to protect personal data, prevent online harassment, and counter misinformation, fake news, and child abuse in the digital space.
The three new criminal laws, the Bharatiya Nyaya Sanhita (BNS), Bharatiya Nagrik Suraksha Sanhita (BNSS), and Bharatiya Sakshya Adhiniyam (BSA), which aim to strengthen India’s legal framework for cybercrime prevention, were also referred to in the address bythe Home Minister. These laws incorporate tech-driven solutions that will ensure investigations are conducted scientifically and effectively.
Mr. Shah emphasised popularising the 1930Cyber Crime Helpline. Additionally, he noted that I4C has issued over 600advisories, blocked numerous websites and social media pages operated by cybercriminals, and established a National Cyber Forensic Laboratory in Delhi. Over 1,100 officers have already received cyber forensics training under theI4C umbrella.
In response to the regional cybercrime challenges, the formation of Joint Cyber Coordination Teams in cybercrime hotspot areas like Mewat, Jamtara, Ahmedabad, Hyderabad, Chandigarh, Visakhapatnam and Guwahati was highlighted as a coordinated response to local cybercrime hotspot issues.
Conclusion
With the launch of initiatives like the Cyber Fraud Mitigation Centre, the Samanvay platform, and the Cyber Commandos Program, I4C is positioned to play a crucial role in combating cybercrime. The I4C is moving forward with a clear vision for a secure digital future and safeguarding India's digital ecosystem.
References:
● https://pib.gov.in/PressReleaseIframePage.aspx?PRID=2053438
