The consultation paper released this month is the first Australian document to treat synthetic media labelling as a general obligation rather than a platform specific one. It is a draft, comments close in October, and most of it will change. It is still worth reading closely.
What it asks for
The core proposal is a disclosure duty: if content is materially synthetic and a reasonable person would be misled without knowing, the publisher discloses it. Disclosure can be visible labelling, embedded metadata, or both.
The paper is deliberately vague about mechanism. It names provenance standards as an acceptable route, without requiring any particular one, and without saying who verifies the claim.
Where the gap is
A disclosure duty with no verification requirement puts the whole weight on self reporting. Publishers acting in good faith will label their work. Publishers acting in bad faith will not, and nothing in the draft makes that detectable.
Labelling tells you what the publisher says. Provenance tells you what you can check. The draft asks for the first and gestures at the second.
This is not an argument for mandating one standard. It is an argument that a disclosure rule without a verification path mostly regulates the people who were never the problem.
What we said in our submission
- Keep the mechanism neutral, but require that disclosures be machine readable.
- Say explicitly that stripping provenance metadata during distribution is a distinct harm.
- Give small publishers a safe harbour where a good faith signed original exists.
Our full submission is available on request. Comments close on 31 October and anyone publishing in Australia should consider making one.