社團指南

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.

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  1. 概述
  2. 深入探討
  3. 戰略影響
  4. The Future of China’s Algorithm Registry and Large Model Filing System
  5. 現實世界的實施
  6. 風險與防護欄
  7. 實施路線圖
  8. 不斷探索
  9. 常見問題

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.

深入探討

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.

戰略影響

風險與安全

災難性和日常的人工智慧危害都取決於誰了解風險以及誰能夠採取行動。

更明確的決策

民眾和專業素養決定強而有力的安全政策在政治上是否可行。

突破炒作

清晰的解釋可以減少炒作、實驗室公關和模糊道德劇場的影響。

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.

現實世界的實施

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.

風險與防護欄

  • 將存在風險視為科幻小說,同時能力複合。

  • 混淆了表面產品安全與高度自治下的對準。

  • 只給非英語和非專業觀眾留下低品質的資源。

實施路線圖

  1. 單獨的產品危害、誤用和失控/失調風險。

  2. 詢問哪些證據會改變您對時間表和嚴重性的看法。

  3. 比起行銷主張,更喜歡主要來源和具體評估。

  4. 確定一條行動路徑:職業、政策、資金或技能——而不僅僅是意識。

不斷探索

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常見問題

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.