Legal Approaches to Deepfakes: Contextualising India’s Intermediary Guidelines Amendments in the Global Regulatory Environment

The article examines India’s 2026 amendments to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules in relation to synthetically generated information, covering deepfake creation and distribution. It first identifies the need for regulation in India, drawing on recent instances of deepfake-related events, and then places those needs in a comparative perspective by analysing regulatory approaches in China, the European Union and the United States. The article argues that India has adopted a hybrid intermediary-liability model that combines labelling, provenance, technical-prevention, user-declaration and accelerated takedown obligations while still relying on existing criminal, electoral, consumer-protection, privacy and personality-rights frameworks to do much of the hard work. By situating India’s framework within the broader global regulatory environment, the article contributes to current debates on how legal systems should respond to harmful synthetic media without unduly constraining other beneficial uses of generative AI. Overall, the analysis shows that India’s Intermediary Guidelines Amendments offer a reasonable response to the main issues at stake but leave considerable room for other areas of law to do the heavy lifting. The article concludes on a cautionary note, highlighting the expected challenges of future implementation.