Table of Contents
Quick Answer
China regulates AI through a vertical stack of Cyberspace Administration of China (CAC) rules in 2026: Algorithm Recommendation Provisions (2022), Deep Synthesis Provisions (2023), Interim Measures for Generative AI Services (August 2023), AI-Generated Content Labelling Measures (September 2025), and a draft national AI Law released by the Chinese Academy of Social Sciences for consultation.
- Every generative AI service for the Chinese public must file with the CAC
- All AI-generated content must carry explicit and implicit labels from 1 September 2025
- Training data must be lawful; content must uphold socialist values
What Is China's AI Regulatory Framework?
China's AI governance is issued jointly by the CAC, MIIT, Ministry of Public Security, and other regulators. The foundational instruments are the Cybersecurity Law (2017), Data Security Law (2021), and Personal Information Protection Law (PIPL, 2021). On top sit AI-specific rules administered primarily by the CAC.
The Interim Measures for the Management of Generative AI Services took effect 15 August 2023 (Order No. 15, CAC). The Administrative Measures for AI-Generated Synthetic Content Labelling (jointly issued by CAC, MIIT, MPS, and NRTA) took effect 1 September 2025. A comprehensive AI Law is on the State Council's 2025-2026 legislative agenda.
Key Details / Requirements
Regulation
Year
Core Scope
Algorithm Recommendation Provisions
2022
Recommendation algorithms (news, e-commerce, short video)
Deep Synthesis Provisions
2023
Deepfakes, face-swap, voice cloning
Interim Measures for Generative AI Services
2023
Public-facing LLMs and image generators
Ethics Review Measures for S&T Activities
2023
Research ethics for high-risk AI
AI-Generated Content Labelling Measures
2025
Mandatory visible and embedded content labels
Draft AI Law
2025-2026
Comprehensive national statute (under review)
Labelling Requirements (Effective 1 September 2025)
Content Type
Explicit Label (human-readable)
Implicit Label (metadata)
AI-generated text
"AI-generated" text or icon visible to user
Required per GB/T 45438-2025
AI-generated image
Visible watermark or caption
Required
AI-generated video
Persistent on-screen marker
Required
AI-generated voice
Spoken or text disclosure at start
Required
Real-World Examples / Case Studies
Baidu's ERNIE Bot, Alibaba's Tongyi Qianwen, ByteDance's Doubao, and iFlytek's Spark — all completed mandatory CAC security assessments and algorithm filings before public launch in 2023-2024.
Tencent Hunyuan — Filed under the Deep Synthesis Provisions for its face-reenactment feature.
Meitu — Fined CNY 500,000 in 2024 for using user photos to train AI without explicit consent, under PIPL Article 66.
What This Means for Businesses
Any company offering generative AI to users in mainland China — domestic or foreign-invested — must:
- File the algorithm under the CAC Algorithm Registry
- Complete a CAC Security Assessment if the service has "public opinion properties or social mobilisation capabilities"
- Implement real-name user verification
- Label all AI-generated content per GB/T 45438-2025
- Maintain training data provenance records
- Refuse outputs that "endanger national security" or "contradict socialist core values"
Compliance Checklist
- Register the algorithm via the CAC's public filing portal
- Complete a Personal Information Protection Impact Assessment (PIPIA) per PIPL Article 55
- Implement explicit and implicit content labels before 1 September 2025
- Obtain separate consent for biometric training data
- Establish a mechanism for users to report illegal content within 24 hours
- Store all service logs for at least 6 months
FAQs
Q: Do foreign companies have to comply?
Yes — any generative AI service targeting users in mainland China must comply, regardless of corporate headquarters.
Q: Is ChatGPT available in China?
No — OpenAI services are not authorised for mainland China access.
Q: What is an algorithm filing?
A CAC registration disclosing algorithm purpose, type, training data, and risk controls; required before public launch.
Q: What are the penalties?
Up to CNY 100,000 and service suspension under the Interim Measures; PIPL penalties reach CNY 50 million or 5% of revenue.
Q: Does the Hong Kong SAR follow these rules?
No — Hong Kong has its own AI guidelines from the PCPD and HKMA.
Q: When will the national AI Law pass?
Expected 2026-2027; the draft is under NPC review.
Q: Are open-source models exempt from labelling?
No — any public-facing deployment must label outputs.
Conclusion
China has one of the world's most comprehensive AI rule-stacks. Companies targeting Chinese users must treat algorithm filing, content labelling, and PIPL compliance as gating requirements.
Misar AI's China AI compliance guide is updated monthly — visit misar.blog/china-ai.