China's Generative AI Rules: Filing, Labelling, Content Control

Who this is for

• Businesses offering a generative service to users in the PRC
• Businesses training or fine-tuning models on PRC territory or with PRC user data
• Exporters who only sell a non-AI product into China and need to know they are probably not in the filing gate

Two different businesses

Selling into China (a physical product, a site with no public generative service, a B2B tool with no PRC public content surface) is mostly product, contract, and, if you process personal information, PIPL. The generative-AI filing gate is not automatically yours.

Training or deploying a public generative service in China: a chatbot, image generator, or similar that the public in the PRC can use, is inside the CAC stack below. “Public opinion attributes or social mobilisation capability” is the phrase the filing duty uses. In practice, a consumer-facing generator is treated as in.

If you only call a China-hosted API from the UK for UK users, you are not thereby a PRC generative-AI provider. If you put a generator on a .cn site or a Chinese app store, you are.

The core instruments (as of 13 August 2026)

Enforcement is real. CAC has run labelling sweeps (including a widely reported February 2026 action). Do not treat “interim” as unenforced.

Filing and security assessment

Before a public generative service goes live in China:

1. Security assessment, submitted through provincial CAC and, for national-reach or public-opinion services, central review.
2. Algorithm filing on the CAC system. You receive a filing number. Display it.
3. Training-data provenance, content filters, watermarking/traceability, real-name registration aligned with existing cybersecurity rules.

Timelines of several months are normal. Using a pre-filed third-party model via API can shorten local registration; it does not skip the analysis of whether your service still needs a filing.

No filing number, no lawful public operation. That is the filing gate.

Labelling

Since 1 September 2025:

• Explicit labels on generated text, image, audio, video and virtual scenes, visible in the content or the interface.
• Implicit labels in the file (provider, content id, generation data), to the GB 45438-2025 method.
• Distribution platforms check labels on upload and warn when content is generated or likely generated.
• Stripping labels to pass content off as human is a violation.

This is stricter and more technical than EU Article 50. Do not assume an Article 50 watermark satisfies GB 45438-2025.

Content control

The Interim Measures still require providers to keep generated output inside PRC content rules (a long prohibited list, including political and national-security categories). Illegal output must be stopped, and serious cases reported. That duty is why a model that is lawful in London can be unlawful on a Shanghai endpoint without a single line of GDPR changing.

Questions

We sell software to a Chinese company that runs the model. Who files?

Usually the provider of the public service in China. If your customer is the one offering the chatbot to the PRC public, they are in the filing seat. If you operate the service, you are. Contract for it. Do not assume the overseas parent can file “for” a PRC service without a PRC entity. Local presence is a practical requirement in most cases. Confirm with PRC counsel.

Does the Interim Measures’ “interim” label mean a replacement is coming?

The title has said 暂行 since 2023. Labelling measures and GB 45438-2025 have grown up around it. As of 13 August 2026 there is no replacement statute that retires the Interim Measures. A future AI law could. This page will say so when one is in force.

We only advertise a UK SaaS site to Chinese tourists. Filing?

A public generator used in the PRC can still be in scope even if the company is abroad, similar extra-territorial pattern to other CAC rules. A brochure site with no generative service is a different question. If the product is the generator, get PRC counsel before the first user in Beijing.

What changed

• 13 August 2026: First publication. Cadence: medium (90–180 days). Next review due 9 January 2027. Off-cycle if the Interim Measures are replaced or CAC issues a new labelling sweep that changes the practical duty.

Note: This is compliance consulting and training, not legal advice. We work alongside your legal counsel, translating regulation into operational reality rather than replacing them. For a structured pass, see AI compliance.