MPTC Issues Public Notice on Synthetic and Manipulated Media

In 2026 the Cambodian authorities issued guidance on the treatment of deepfake and synthetic media content that circulates through telecommunications channels and digital platforms. The guidance responds to the growing sophistication of tools that generate realistic but fabricated audio, video and images, and to the potential for such content to affect elections, public order, financial markets, personal reputation and consumer protection.

The guidance is relevant to telecommunications operators, digital platforms, media organisations, public authorities and, indirectly, to the users whose experience of digital content is affected by the presence of synthetic material.

The guidance addresses content that has been generated or materially altered using artificial intelligence in a way that makes the content appear authentic when it is not. It distinguishes between clearly fictional or artistic uses of synthetic media, which raise fewer concerns, and deceptive uses that could mislead recipients about the identity of individuals depicted, the events shown or the source of the content.

The guidance does not seek to regulate every use of AI-generated content but focuses on categories where the potential for harm is significant. It complements other frameworks addressing defamation, fraud, election integrity and consumer protection.

Platforms that host or distribute content, including social media, messaging services and content aggregators, are expected to have mechanisms to identify and respond to reports of deceptive synthetic content. Responses may include labelling, restricting distribution, removing content that violates applicable rules and providing information to affected individuals about the actions taken. The specific measures should be proportionate to the risk and consistent with freedom of expression.

Telecommunications operators that carry traffic without hosting or curating content have different responsibilities and are not expected to filter individual messages. They can nevertheless support the broader effort by cooperating with authorities on specific matters, by supporting user awareness and by ensuring that services they provide, such as messaging platforms, incorporate appropriate protections.

Labelling is one of the primary tools contemplated by the guidance. Content identified as synthetic can be marked so that users are alerted to its nature, allowing them to interpret it appropriately. Labelling can be applied automatically where technical indicators are available or manually where the content has been reviewed. Coordination on labelling standards supports consistency across platforms.

Transparency by creators of synthetic content is also encouraged. Where the content is intended for legitimate purposes such as advertising, education or entertainment, clear disclosure that the content is synthetic supports informed engagement.

The guidance encourages the development of notice mechanisms through which individuals affected by deceptive synthetic content can request review. These mechanisms should be accessible, should support timely response and should provide appropriate remedies when concerns are validated. Individuals depicted in synthetic content without consent may have specific rights under applicable rules, including data protection and civil law.

Platforms should keep records of notices received and actions taken, both to support internal governance and to provide information to authorities where appropriate.

Content relating to elections, public officials and other matters of public interest is treated with particular care. The guidance encourages platforms to have enhanced processes during election periods, to cooperate with electoral authorities and to provide clear information to users about the origins and authenticity of political content. The objective is to protect democratic processes without unduly restricting legitimate political speech.

Public authorities themselves are expected to communicate authoritatively during periods of heightened risk, to provide clear information about official positions and to cooperate with platforms and media organisations on responses to specific incidents.

Synthetic content is increasingly used in fraud, including impersonation of executives, family members and public figures to deceive victims into transferring money or disclosing sensitive information. The guidance encourages coordinated responses involving platforms, telecommunications operators, financial institutions and law enforcement.

Awareness campaigns can support consumer resilience by helping individuals recognise the warning signs of deceptive synthetic content and by providing clear guidance on the steps to take when suspicious content is encountered.

Individuals depicted in synthetic content without their consent may have rights under applicable rules, including data protection, personality rights and civil law. The guidance encourages platforms to support the exercise of these rights and to cooperate with authorities and legal representatives. Sensitive categories such as non-consensual intimate imagery are treated as high priority.

Legal support for affected individuals, including through civil society organisations and specialist legal services, is an important complement to platform responses.

Synthetic content frequently crosses borders, and effective responses require cooperation between national authorities, international counterparts and global platforms. The guidance encourages engagement with international frameworks and with regional initiatives, including sharing of information about emerging threats and coordination on standards for detection and labelling.

Cambodian authorities are expected to engage constructively with these efforts, adapting international good practice to the local context and contributing local perspectives to global discussions.

For platforms and operators, the guidance calls for a review of internal policies, technical tools, notice mechanisms and cooperation arrangements. Cross-functional coordination between trust and safety, legal, communications and technical teams supports coherent responses to incidents and to systemic issues.

For enterprises, media organisations and public authorities, the guidance offers a framework for building resilience against synthetic content and for engaging effectively with platforms and other stakeholders.

Lex Civora advises telecommunications operators, digital platforms, media organisations and enterprises on the interpretation and application of the deepfake content guidance, on the design of internal policies and notice mechanisms and on responses to specific incidents affecting individuals or organisations in Cambodia.