China does not regulate AI through one comprehensive code. Its national framework is layered by function and audience. A company must identify whether it serves the mainland public, what its system does (generate, recommend, synthesize, or simulate emotional interaction), whether it distributes content, and whether the service can influence public opinion or mobilize society.
The main national instruments are the Algorithm Recommendation Provisions (effective 1 March 2022), Deep Synthesis Provisions (10 January 2023), Generative AI Interim Measures (15 August 2023), AI-Generated Synthetic Content Labeling Measures (1 September 2025), and Anthropomorphic AI Interaction Services Interim Measures (15 July 2026). These rules operate alongside China’s cybersecurity, data-security, personal-information, intellectual-property, sector-licensing and other laws.
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The national AI rules at a glance
The table below shows what each instrument covers and when it became effective. A single product can fall under several rows at once.
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| Algorithm Recommendation Provisions | 1 March 2022 | Recommendation, ranking, search, filtering, personalized distribution, generation and synthesis algorithms | Algorithm safety, user disclosures, non-personalized or opt-out choices, and conditional filing |
| Deep Synthesis Provisions | 10 January 2023 | Generated or edited text, voice, music, sound, faces, images, video, digital people and virtual scenes | User registration, input/output review, records, biometric-consent controls, labels and assessments for specified services |
| Generative AI Interim Measures | 15 August 2023 | Generative AI services offering text, image, audio, video or similar content to the mainland public | Lawful data, intellectual property, personal information, content security, complaints and conditional assessment/filing |
| AI-Generated Synthetic Content Labeling Measures | 1 September 2025 | Covered providers, distributors and app stores under the algorithm, deep-synthesis and generative-AI regimes | Visible notices, hidden file metadata, export handling and platform checks |
| Anthropomorphic AI Interaction Services Interim Measures | 15 July 2026 | Continuous emotional-interaction services that simulate human personality, thought and communication | Identity disclosure, exit routes, anti-dependence safeguards, minor protection, assessments and annual verification |
First decide whether your product is in scope
Scope is determined by the service offered, not simply by whether a company uses a machine-learning model. The most important distinction is between a public service and an internal or research use.
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Public service to mainland users
The Generative AI Interim Measures cover use of generative AI to provide the mainland public with generated text, images, audio, video or other content. A hosted chatbot, image generator or public application normally requires a detailed review against these measures. The rules also preserve special requirements for activities such as news publishing, film and television production, and literary or artistic creation.
Internal research and private applications
Research and development, or an application that does not provide a generative-AI service to the mainland public, is outside the stated scope of the Generative AI Interim Measures. That is not a blanket exemption from Chinese law. Internal deployments can still involve personal information, important data, cybersecurity, intellectual property, employment, finance, healthcare or other sector rules.
Overlapping functions
A product may generate an answer, rank information, edit a face, distribute user posts and maintain an emotionally continuous persona. Each function should be mapped separately. The relevant question is not whether the supplier calls the product a “model,” but which internet information service the company actually provides.
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The Generative AI Interim Measures assign responsibilities across data preparation, model operation and user support. Treat the obligations as a lifecycle program rather than a one-time launch filing.
Use lawful, defensible data
- Use training data and foundation models from lawful sources and respect intellectual-property rights.
- Meet personal-information requirements, including consent or another lawful basis where Chinese law requires one.
- Improve training-data quality and establish workable annotation rules, review procedures and quality checks.
Protect content and information
Providers assume network-information content-producer responsibilities and must fulfill information-security duties. Where personal information is involved, they also act as personal-information handlers. Controls should cover prompts, uploaded files, generated results, logs, moderation records and access to operational systems.
Tell users what the service does
Providers must publish the applicable users, settings and uses of the service. They must protect user inputs and usage records, avoid collecting unnecessary personal information, and handle requests to access, copy, correct, supplement or delete personal information.
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Operate a responsive service
The service must be safe and stable. Providers need a complaint channel, a process for acting when illegal content is found, and controls that prevent or remove unlawful outputs. The relevant deep-synthesis labeling requirements also apply where the generated material falls within that regime.
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The Algorithm Recommendation Provisions are broader than generative AI. They cover generation and synthesis, personalized push, ranking and selection, search and filtering, and dispatch or decision algorithms.
Baseline duties for recommendation providers
Providers must maintain algorithm-safety and review controls, manage unlawful information, and disclose that algorithmic recommendation is being provided. Disclosures must explain the basic principles, purposes and operating mechanisms in a form users can understand. Users must be offered a way to opt out or choose non-personalized recommendations.
The public-opinion and social-mobilization trigger
A provider whose service has public-opinion attributes or social-mobilization capacity must file through the algorithm filing system within ten working days after commencing the service. It must update or cancel the filing when required. This is a conditional duty, not a universal registration requirement for every model or recommendation feature.
What deep-synthesis services add
The Deep Synthesis Provisions apply to internet information services in China that generate or edit text, voice, music, other sound, faces, images, video, digital people or virtual scenes.
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Providers must maintain user-registration and review systems, examine inputs and outputs, keep relevant records, and manage training data and personal information. The controls should cover both the material a user submits and the synthetic result returned by the service.
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Face and voice editing
For tools that edit facial or voice biometric information, users must be prompted to notify the person concerned and obtain separate consent where the rule requires it. A product that can put a real person’s face or voice into new material therefore needs a consent workflow, not just a general terms-of-service clause.
Assessments and filings
Certain biometric or sensitive-scene models and tools require a security assessment. Services with public-opinion attributes or social-mobilization capacity have algorithm-filing obligations, and specified new products, applications or functions require an assessment before launch. The exact trigger depends on the service and function.
How the 2025 labeling rules work
The AI-Generated Synthetic Content Labeling Measures took effect on 1 September 2025. They apply to covered network-information service providers under the algorithm, deep-synthesis and generative-AI rules and extend responsibilities to downstream distribution.
Visible labels
A visible label is perceptible to users in text, sound, graphics or an interaction interface. Covered content must display a notice in the appropriate location. The label should remain understandable when the material is viewed in the service’s ordinary interface.
Hidden labels and metadata
Generated-content files must contain hidden metadata with identifying production information. The measures state that hidden labels may include content attributes, the provider’s name or code, and a content number. Digital watermarking is encouraged, but a hidden label is not automatically the same thing as a watermark: the rule specifically addresses file metadata and separately encourages watermarking.
Exports, distributors and app stores
Exported files must retain required visible marks where applicable. 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 the relevant labeling materials.
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User declarations
When users post generated content, they must declare that fact and use the provider’s labeling function. A platform therefore needs both a provider-side labeling mechanism and a user-facing declaration flow.
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When the 2026 anthropomorphic-AI rule applies
The Anthropomorphic AI Interaction Services Interim Measures took effect on 15 July 2026. They target continuous emotional interaction with mainland users that simulates human personality traits, thought patterns and communication style, including companionship, emotional care and support through text, image, audio or video.
Services covered
A virtual companion that maintains an ongoing relationship, presents a simulated personality and encourages emotional reliance is the central example. Providers must manage safety during deployment, operation, upgrades and termination; protect interaction data; make the AI identity clear; provide an exit route; and address overreliance, emotional dependence and risks to minors.
Services generally outside this measure
Ordinary customer service, factual question answering, work assistance, education and scientific research are excluded when they lack continuous emotional interaction. The exclusion is function-specific: adding a persistent companion mode can bring an otherwise ordinary assistant into scope.
Minors and assessment thresholds
Virtual family-member or partner services for minors are barred. Specified cases require guardian consent and a minor mode. A safety assessment is required for launch or addition of a related function, a material service change caused by new technology or an application, reaching 1 million registered users or 100,000 monthly active users, specified safety risks, or another regulator-designated situation. Covered providers also need algorithm filing and annual verification.
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Do foreign companies need to file with the CAC?
There is no blanket yes-or-no answer. A foreign company serving mainland users must classify its actual service under the same functional rules. If the service has public-opinion attributes or social-mobilization capacity, the applicable algorithm-filing and security-assessment duties can arise. A deep-synthesis service may also face biometric, sensitive-scene or new-function assessment requirements. A routine internal tool that never provides a mainland public service may fall outside the Generative AI Interim Measures, but that conclusion does not remove other Chinese legal obligations.
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The Generative AI Interim Measures state that foreign-invested generative-AI services must comply with foreign-investment laws and regulations and obtain any administrative license otherwise required. Those clauses do not replace a fact-specific review of sector licensing, data transfers, cybersecurity or market-entry restrictions.
Keep filing, registration, assessment and licensing separate
- Algorithm filing: a procedural filing for qualifying recommendation or related services, including the ten-working-day timing after commencement for services with public-opinion or social-mobilization capacity.
- Application or function registration: a separate status reflected in later CAC announcements for certain launched applications or functions.
- Security assessment: a substantive review required for specified generative-AI, deep-synthesis or anthropomorphic-service triggers.
- Administrative license: a sector or activity permission that may be required independently of AI filing or assessment.
Calling all four processes “registration” can cause a company to miss a required assessment or assume that a filing substitutes for a license.
A practical compliance workflow
- Describe the service precisely. Record users, geography, outputs, interaction style, distribution channels and whether the system ranks or recommends information.
- Map every function. Check generation, recommendation, deep synthesis, biometric editing, content distribution, app distribution and continuous emotional interaction separately.
- Test the public-opinion trigger. Document whether the service can shape public opinion or mobilize society. Do not assume that all consumer AI has this capacity.
- Inventory data and rights. Identify training sources, personal information, biometric material, intellectual-property permissions, annotation controls and retention periods.
- Design user controls. Add disclosures, non-personalized or opt-out choices where required, consent prompts for covered face or voice editing, personal-information rights handling and complaint channels.
- Implement labeling end to end. Generate visible notices, embed required metadata, preserve marks on export, inspect incoming metadata and support user declarations.
- Schedule assessments and filings. Check launch, new-function, material-change, user-threshold and public-opinion triggers before release, then maintain updates, cancellations and annual verification where applicable.
- Review adjacent laws. Confirm cybersecurity, data-security, personal-information, intellectual-property, sector licensing, foreign-investment and any local requirements with qualified Chinese counsel.
What the latest official counts mean
In a 14 September 2026 announcement, the Cyberspace Administration of China reported 1,112 filed generative-AI services and 731 registered AI applications or functions as of 31 August 2026. It said 124 services and 133 applications or functions were added during July and August. The announcement also said launched applications or functions should display the filed or registered service they use, including the model name and filing or launch number.
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Those figures describe CAC-reported filings and registrations. They are not a census of every AI product, model, company or internal deployment operating in China, and they do not establish that every service follows the same procedure.
What companies should document before launch
A defensible file should show why the company classified the product as public or internal, which rules apply to each function, how data and intellectual-property rights were checked, how outputs are reviewed, how labels survive export, and which assessment, filing, registration or license pathway was used. Keep evidence of user notices, consent, complaints, incidents, model changes and regulator communications. The national AI instruments are intentionally layered, so a product can be compliant with one rule and still require work under another.
China’s approach is therefore best understood as classified and tiered regulation: public-facing services receive the closest scrutiny, high-impact distribution and mobilization functions trigger additional procedures, synthetic media must be traceable to its producer, and emotionally anthropomorphic systems receive dedicated safeguards. A launch decision should be based on the product’s functions and users, not on a generic label such as “AI model.”
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