AI Regulation in China
China has enacted the most prescriptive and rapidly evolving AI regulatory framework in the Asia-Pacific region. Three major regulations apply to AI services accessible to Chinese users: the Algorithm Recommendation Regulations (2022) covering content recommendation systems; the Deep Synthesis Regulations (2022) requiring labeling of AI-generated images, video, and audio; and the Generative AI Regulations (2023) imposing security assessments and real-name registration on providers of publicly accessible generative AI services. All are administered by the Cyberspace Administration of China (CAC).
The Generative AI Regulations are the most operationally significant for international organizations. Services offering generative AI capabilities to users in China must complete a security assessment and register with the CAC before public launch. Training data must comply with labeling obligations, and outputs must carry disclosure notices. The regulations apply to foreign companies serving Chinese users, not just domestic operators.
China's regulatory model reflects priorities distinct from Western frameworks: content control, algorithmic sovereignty, national security alignment, and Communist Party oversight sit alongside technical safety requirements. The compliance stack operates largely independently of the EU AI Act or NIST AI RMF, requiring organizations with Chinese market presence to maintain a separate compliance program tailored to CAC requirements and the political dimensions of AI governance in China.
Key themes
- 1.Generative AI registration and security assessments (CAC)
- 2.Deep synthesis labeling obligations for AI-generated media
- 3.Algorithm recommendation filing requirements
- 4.National security and content control obligations
Regulatory frameworks and guidance(3)
China Algorithm Recommendation Regulations
China's first dedicated regulation governing algorithmic recommendation systems, imposing transparency, user-control, and content-moderation obligations on providers of internet-based recommendation services operating in or targeting users in China.
China Deep Synthesis Regulations
China's Provisions on the Administration of Deep Synthesis Internet Information Services regulate the development, distribution, and use of deep synthesis technologies-including AI-generated or AI-manipulated text, images, audio, video, and virtual humans-by service providers and users operating in or targeting China. They impose labelling, registration, security-assessment, and content-moderation obligations.
Interim Measures for the Management of Generative Artificial Intelligence Services
China's Interim Measures for the Management of Generative AI Services impose mandatory obligations on providers of generative AI products and services to the Chinese public, covering training data governance, content safety, algorithmic transparency, and registration requirements.