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概述
The filing regime is distinct from security assessment and service requirements, and does not apply identically to every model or internal AI tool.
深入探讨
China’s algorithm filing framework is built from several rules. The 2022 Algorithm Recommendation Provisions require algorithm-recommendation service providers with public-opinion or social-mobilization capacity to file through the national system within ten working days of providing the service, and to update or cancel filings when circumstances change. The Deep Synthesis Provisions extend filing and change/cancellation procedures to covered deep-synthesis providers and, by reference, technical supporters. These rules are tied to internet information services provided within China and particular capability thresholds. The 2023 Interim Measures for Generative AI Services add a separate requirement: providers offering generative-AI services with public-opinion attributes or social-mobilization capacity must conduct a security assessment and complete algorithm filing under applicable rules. Filing is therefore not the same as approval of all product functions, and a filing number does not show that every legal obligation has been satisfied. Providers also have content-management, data, user-service, and security duties under the relevant instruments. Some rules distinguish services offered to the public in China from research, development, or internal use that is not provided to the public. A company should map whether it is a service provider, technical supporter, or another actor; whether the service uses recommendation, deep-synthesis, or generative algorithms; whether it is offered within China; and whether it has public-opinion or social-mobilization capacity. If the threshold is met, identify the filing authority, deadline, and supporting materials, and check whether a security assessment is separately required. Changes to algorithm type, service, provider, or public capability can trigger amendment or cancellation procedures. The CAC maintains public filing notices and updates, including batches of registered algorithms and some cancellations. These records show filed services, not a comprehensive registry of all AI development. Do not infer filing status from model popularity or a company’s press release; check the official registry and the current rule text.
战略影响
风险与安全
灾难性和日常的人工智能危害都取决于谁了解风险以及谁能够采取行动。
更清晰的判决
公众和专业素养决定强有力的安全政策在政治上是否可行。
打破炒作
清晰的解释可以减少炒作、实验室公关和模糊道德剧场的影响。
The Future of China’s Algorithm Registry and Large Model Filing System
The CAC continues to publish filing batches, cancellations, and new measures for particular service types. Requirements can differ across recommendation, deep-synthesis, generative-AI, and newer interactive services. Providers should monitor the official filing system and current Chinese rules before each public launch or material product change. A filing record supports transparency about a covered service, while ongoing content, privacy, security, and user-protection duties remain separate. Public notices can identify the operator, service type, and filing number, but do not amount to a general product endorsement or a complete inventory of all AI research. Maintain a dated record of the regulator notice used for each launch decision.
现实世界的实施
A short-video platform checks whether its recommendation service can shape public opinion and completes an algorithm filing if covered.
A public generative-AI chatbot separately assesses whether it needs a security assessment and algorithm filing.
A deep-synthesis provider submits a filing change after materially changing the service or algorithm type.
A product team checks CAC’s official list rather than assuming a research model has a public-service filing.
风险与防护栏
将存在风险视为科幻小说,同时能力复合。
混淆了表面产品安全与高度自治下的对准。
只给非英语和非专业观众留下低质量的资源。
实施路线图
单独的产品危害、误用和失控/失调风险。
询问哪些证据会改变您对时间表和严重性的看法。
比起营销主张,更喜欢主要来源和具体评估。
确定一条行动路径:职业、政策、资金或技能——而不仅仅是意识。
不断探索
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常见问题
What is China’s Algorithm Registry and Large Model Filing System?
China requires certain internet information services with public-opinion or social-mobilization capabilities to file covered recommendation, deep-synthesis, or generative-AI algorithms with the Cyberspace Administration of China. The filing regime is distinct from security assessment and service requirements, and does not apply identically to every model or internal AI tool.
Which services are subject to the algorithm filing rule described in the guide?
The filing trigger is tied to service type and public-opinion or mobilization capacity.
Is a security assessment the same as an algorithm filing?
The generative-AI measures distinguish assessment from filing.
Who should a deep-synthesis technical supporter consider in its filing analysis?
The Deep Synthesis Provisions address providers and technical supporters.
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