China Requires Two-Step Compliance Process Before Public Generative AI Launch
China's Cyberspace Administration, along with six other central departments, issued the Interim Measures for the Management of Generative AI Services in July 2023, which took effect in August 2023. The rules apply to any generative AI service offering text, image, audio, or video content to the public within mainland China, with exemptions for internal tools and services not targeting domestic users. Providers whose services carry public opinion attributes or social mobilisation capability face an additional two-stage obligation: a security self-assessment submitted to cyberspace and public security authorities, followed by a separate algorithm filing through the CAC's online system. Regulators treat most public-facing generative AI platforms as falling within the scope of these attributes, making the dual requirement broadly applicable in practice. Experts caution that the two steps are sequential and interdependent, and that providers should seek dedicated Chinese legal counsel before launching any service in the market.
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