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China regulates AI through a layered set of national rules rather than one comprehensive AI law. For a company, the first question is not simply whether a product uses AI: it is what the service does, whether it serves the public in mainland China, and whether it generates or distributes content, recommends information, or provides continuous emotional interaction.
The framework includes rules for algorithm recommendations, deep synthesis, public generative-AI services, AI-generated-content labels, and anthropomorphic AI interaction services. A product can fall under more than one set of rules, and these AI-specific requirements operate alongside applicable cybersecurity, data, privacy, intellectual-property, licensing, and sector rules.
How to determine which China AI rules apply
Start with the service and its users, not the model name. The same model may be used in an internal tool, a public chatbot, a recommendation feed, or an AI companion; those deployments can have different regulatory consequences. The national rules discussed here concern mainland China. They do not establish that every company using AI, or every AI model, must complete the same filing or assessment.
- Identify the deployment and audience. Is the system being researched or used internally, or does it provide a service to the mainland public? The Generative AI Interim Measures cover public services that generate content; they expressly exclude R&D and applications that do not provide such a public service. That exclusion is limited to those Measures and does not waive other applicable laws.
- Classify the function. Check whether the service generates content, edits or synthesizes media, ranks or recommends information, or provides ongoing emotional interaction that simulates a person. A product can have several of these functions.
- Assess the service’s reach and influence. Determine whether it has public-opinion attributes or social-mobilization capacity. That characteristic is a trigger for security assessment and algorithm-filing duties in the relevant rules; it is not a universal filing requirement for all AI products.
- Map the company’s role. A model or service provider, a downstream application operator, a content-distribution platform, and an app-distribution service may have different duties under the applicable provisions.
- Check the launch and change conditions. A new product, function, or material service change may have assessment or filing consequences. Also determine whether the activity is subject to sector-specific rules or an administrative license.
This is a classification framework, not a substitute for reviewing a particular product’s design, users, data flows, and deployment arrangements. The national texts reviewed are in Chinese; English descriptions of their requirements are working translations.
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Which national instruments make up the framework?
The core rules came into effect in stages. Their subject areas overlap: for example, a public generative-AI service that synthesizes video and recommends content may need to consider several instruments, rather than choosing only one.
| Instrument | Effective date | What it regulates | Important trigger or focus |
|---|---|---|---|
| Provisions on the Administration of Algorithm Recommendation in Internet Information Services | 1 March 2022 | Internet information services using recommendation algorithms, including generation or synthesis, personalized push, ranking or selection, search or filtering, and dispatch or decision algorithms. | Public-opinion attributes or social-mobilization capacity trigger filing duties under the provisions. |
| Provisions on the Administration of Deep Synthesis of Internet Information Services | 10 January 2023 | Internet services using technologies to generate or edit text, voice, music and sound, faces, images, video, digital people, and virtual scenes. | Includes user and content management, labeling, and specified assessment and filing requirements. |
| Interim Measures for the Administration of Generative Artificial Intelligence Services | 15 August 2023 | Generative AI services providing the mainland public with generated text, images, audio, video, or similar content. | Public-service scope matters; qualifying services with public-opinion attributes or social-mobilization capacity have assessment and filing duties. |
| Measures for Labeling AI-Generated Synthetic Content | 1 September 2025 | Visible and hidden labeling of covered AI-generated synthetic content, along with duties for relevant service providers and distributors. | Addresses file metadata, exported content, content distribution, and app distribution. |
| Interim Measures for the Administration of Anthropomorphic AI Interaction Services | 15 July 2026 | Services to the mainland public that provide continuous emotional interaction by simulating human personality traits, thought patterns, and communication style. | Focuses on emotional interaction and related safety safeguards; ordinary tools without continuous emotional interaction are outside this measure. |
The Algorithm Recommendation Provisions were issued on 31 December 2021 by four agencies. The Deep Synthesis Provisions were issued on 25 November 2022 by the CAC, MIIT, and Ministry of Public Security. The Generative AI Interim Measures were issued on 10 July 2023 by the CAC and six other central agencies. The labeling measures were issued on 7 March 2025 by four agencies, and the anthropomorphic-interaction measures were issued by the CAC on 10 April 2026.
What the rules require from public generative-AI providers
The Generative AI Interim Measures cover services that use generative AI to provide the mainland public with generated text, images, audio, video, or other content. Research and development, or an application that does not provide this kind of public service, falls outside the scope of these particular Measures. That is not a blanket exemption from China’s other laws, and it does not settle whether a specific internal deployment is covered by other rules.
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Data, models, and personal information
Providers must use training data and foundation models from lawful sources, respect intellectual-property rights, and meet personal-information requirements, including obtaining consent or using another lawful basis where required. They must improve data quality and establish workable rules and checks for data annotation. Where personal information is involved, the Measures also place personal-information-handler responsibilities on the provider.
Content and service operations
Providers have network-information content producer responsibilities and must fulfill information-security duties. They must make the service’s applicable users, settings, and uses public; protect user inputs and usage records; avoid collecting unnecessary personal information; and handle requests to access, copy, correct, supplement, or delete personal information. They must provide safe and stable services, respond to complaints, and act when illegal content is found.
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The Measures preserve applicable special rules for activities such as news publishing, film and television production, and literary or arts creation. They also state that foreign-invested generative-AI services must comply with foreign-investment laws and regulations, and that any otherwise-required administrative license must be obtained. Those provisions do not establish that every foreign company must file with the CAC, nor do they resolve market-entry or licensing questions for a particular business.
When filing and security assessment are required
Filing, registration, security assessment, and an administrative license are distinct concepts in this framework. The trigger described in the algorithm, deep-synthesis, and generative-AI rules is generally a service with public-opinion attributes or social-mobilization capacity, not simply the fact that a model exists or produces AI output.
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The Algorithm Recommendation Provisions cover more than personalized feeds. Their definition includes generation and synthesis, personalized push, ranking and selection, search and filtering, and dispatch or decision algorithms. Providers must maintain algorithm-safety and review controls, manage unlawful content, disclose that recommendations are being provided and explain their basic principles, purposes, and operating mechanisms. They must give users an option to opt out or select non-personalized recommendations.
Providers in the specified public-opinion or social-mobilization category must file through the algorithm-filing system within ten working days after commencing the service. The provisions also require filing updates or cancellation when applicable. The Generative AI and Deep Synthesis Provisions refer qualifying services back to this framework. Do not treat the ten-working-day deadline or the filing obligation as applicable to every AI model or service.
Deep-synthesis assessment and controls
The Deep Synthesis Provisions apply to covered internet information services using deep-synthesis technologies in China. They require user registration and review systems, examination of inputs and outputs, relevant recordkeeping, and controls for training data and personal information. For face or voice biometric editing, users must be prompted to notify the person concerned and obtain separate consent as required by the rule.
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Certain biometric or sensitive-scene models and tools require a security assessment. Public-opinion or social-mobilization services have algorithm-filing obligations, and specified new products, applications, or functions also require a security assessment before launch. Whether a particular feature falls into one of these specified cases depends on its function and circumstances.
Generative-AI assessment
A generative-AI provider whose service has public-opinion attributes or social-mobilization capacity must conduct a security assessment and fulfill the applicable algorithm filing, change, or cancellation formalities. This is a conditional duty, not a general rule that all public generative-AI services must complete identical procedures.
What AI-generated-content labeling means in practice
The labeling measures, effective 1 September 2025, apply to covered network-information service providers under the algorithm, deep-synthesis, and generative-AI provisions. They distinguish visible labels, which users can perceive, from hidden labels embedded in file data.
Visible labels
Visible notices may appear in text, sound, graphics, or an interaction interface. The measures require notices for specified content types in appropriate locations. When a generated file is exported, required visible marks must be retained where applicable. The exact placement depends on the type of content and the relevant requirement; the measures should not be reduced to a single generic watermark rule.
Hidden labels and distribution
Generated-content files must contain hidden metadata with identifying production information. The measures say hidden labels may include content attributes, a provider name or code, and a content number. Digital watermarking is encouraged as a form of hidden label, but a hidden label is not necessarily a watermark: metadata is specifically addressed.
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Content-distribution services must inspect metadata and add notices in specified cases. App-distribution services must ask whether an app offers generation or synthesis and check relevant labeling materials. Users who post generated content must declare that status and use the provider’s labeling function. These obligations make labeling a lifecycle issue involving generation, export, posting, and distribution—not just a display choice in the model interface.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Which AI companions are covered by the 2026 measure?
The Anthropomorphic AI Interaction Services Interim Measures took effect on 15 July 2026. They apply to services for the mainland public that provide continuous emotional interaction while simulating human personality traits, thought patterns, and communication style. The covered interactions may use text, images, audio, or video and include companionship, emotional care, and support.
Ordinary customer service, factual question-and-answer, work assistance, education, and scientific research are outside this measure when they lack continuous emotional interaction. A chatbot’s label or marketing description alone does not answer the scope question; the relevant distinction is the service’s function and interaction pattern.
Safeguards and assessments
Covered providers must manage safety through deployment, operation, upgrades, and termination; protect user interaction data; make clear that users are interacting with AI; provide an exit route; and address risks of overreliance, emotional dependence, and harm to minors.
The measure bars virtual family-member or partner services for minors. It also imposes guardian-consent and minor-mode requirements in specified cases. A security assessment is required in circumstances that include launching a covered service or adding a related function, a material service change resulting from new technology or application, reaching one million or more registered users, reaching 100,000 or more monthly active users, specified safety risks, or another situation designated by regulators. The measure also requires algorithm filing and annual verification.
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What the official filing figures do—and do not—tell companies
In an announcement published on 14 September 2026, the Cyberspace Administration of China reported that, by 31 August 2026, 1,112 generative-AI services had been filed and 731 AI applications or functions had been registered. The announcement said 124 services and 133 applications or functions were added during July and August. It also said launched applications or functions should display the filed or registered service they use, including the model name and filing or launch number.
These are CAC-reported counts of filings and registrations, not a count of every AI product or every company using AI in China. The announcement’s reference to both filed services and registered applications or functions is another reason not to use “registration” and “filing” as if they were interchangeable procedures.
How to use this framework for a product review
A company assessing a planned launch can use the following sequence to organize a scope review. It helps identify the relevant questions, but does not replace a legal assessment of the specific facts.
- Map users and geography. Record whether the product is available to the mainland public, restricted to employees, or limited to research and development. For a foreign company, separately review foreign-investment and market-entry requirements; public-facing scope alone does not decide them.
- Inventory features, not just models. Document text, image, audio, video, biometric editing, ranking, recommendation, and continuous emotional-interaction functions. Check how each function changes during upgrades or when combined with other features.
- Identify every operational role. Record who supplies the model, operates the user-facing service, distributes content, and distributes the app. Assign ownership for input and output review, records, complaints, privacy requests, and labeling.
- Test the conditional triggers. Assess whether the service has public-opinion attributes or social-mobilization capacity; whether a deep-synthesis function falls within a specified assessment case; and, for anthropomorphic interaction, whether a launch, change, user threshold, or safety risk triggers assessment.
- Build required controls into the product lifecycle. Match applicable obligations to data sourcing, consent or other lawful basis, annotation checks, content review, user disclosures, non-personalized recommendation choices, complaint handling, and visible and hidden labels.
- Keep procedures separate in launch planning. Track security assessment, algorithm filing or changes, any registration relevant to an application or function, and any administrative license as separate items with their own scope and timing.
The AI-specific rules sit alongside cybersecurity, data-security, personal-information, intellectual-property, and sector-specific requirements. The instruments discussed here therefore provide a practical national framework for classification, not an exhaustive inventory of every applicable rule or local implementation.
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