Articles & Insights

Original AI law research from Geason: algorithm filing, data compliance, global expansion, IP, compute and capital governance, with usable conclusions.

Equity Incentives and Debt Financing for AI Companies in China: Where the Two Decisions Collide

2026.10.28

An option pool and a bank facility are usually negotiated by different people at different times, yet both run through the same cap table. This article sets out how Chinese AI companies size and paper an ESOP, when the tax deferral under Caishui [2016] No. 101 applies and where it fails, what lenders actually diligence in a debt financing, and the three points where the two instruments collide.

Hiring Across Borders: Employment and Tax Exposure for AI Companies

2026.10.28

An AI company that hires a engineer in another country, or sends one abroad for six months, creates two exposures at once: an employment-law question about who is the lawful employer, and a tax question about whether the company has just acquired a taxable presence. This article covers employing entities, EOR and secondment structures, work permits and social insurance, permanent establishment risk from engineers and from API sales, transfer pricing and revenue characterisation.

MIIT's Special Action to Cultivate AI Application Service Providers: Positioning, Four Tasks and Compliance Capability Requirements

2026.09.01

On 31 August 2026, the General Office of the Ministry of Industry and Information Technology issued the Notice on Carrying Out the Special Action to Cultivate AI Application Service Providers (MIIT General Office Science and Technology Letter [2026] No. 414). The Notice defines the scope of 'AI application service providers' for the first time, sets targets of more than 2,000 providers in the resource pool by the end of 2026 and no fewer than 3,000 by the end of 2027, and arranges four tasks: building the resource pool, improving service supply, promoting large-scale application and strengthening support. This article reviews the positioning, tasks and compliance requirements relevant to AI companies.

China's Action Plan for High-Quality Development of Cyberspace Enterprises: Policy Upside and Compliance Baselines for AI Companies

2026.08.22

On 21 August 2026, China's cyberspace portal published the Action Plan for Promoting the High-Quality Development of Cyberspace Enterprises (2026-2030). Built around cultivating and serving quality cyberspace enterprises, the plan sets out five actions — tiered cultivation, innovation capability, industrial upgrading, overseas market expansion and safe and orderly development — signalling policy support for AI key-technology research and overseas compliance services, while setting out regulatory requirements on comprehensive algorithm governance and preventing disorderly competition. This article reviews the provisions relevant to AI companies.

China's Network Data Security Risk Assessment Measures Take Effect: Annual Assessment and Reporting for Important Data Processors

2026.08.21

On 20 August 2026, the Measures for Network Data Security Risk Assessment (Order No. 24 of three departments), jointly issued by the Cyberspace Administration of China, the Ministry of Industry and Information Technology and the Ministry of Public Security, took effect. The Measures establish an annual risk-assessment duty for important data processors, a reporting and verification mechanism for assessment reports, and independence requirements for third-party assessment institutions. This article reviews the assessment subject, frequency, reporting and key compliance points, and their implications for AI companies.

Filing for Face-Recognition Technology: The 100,000-Person Threshold, Five Documents and the Non-Mandatory Principle

2026.08.13

The Measures for the Security Management of the Application of Face-Recognition Technology (Order No. 19 of the Cyberspace Administration of China and the Ministry of Public Security) took effect on 1 June 2025. The Measures set the filing trigger at the storage of face information of 100,000 people, require filing with the cyberspace authority at or above the provincial level within 30 working days, and require five categories of documents. This article reviews the filing trigger, document list, the non-mandatory principle and processing rules, and their implications for AI companies.

New Duties for 'Large Personal Information Processors': Greater Scale, Greater Responsibility

2026.08.08

On 7 August 2026 the Cyberspace Administration of China opened public consultation on the Provisions on Personal Information Protection by Large Personal Information Processors (Draft for Comment), with comments due by 7 September. The draft consolidates two earlier drafts on 'large online platforms' and sets dedicated obligations for operators processing the personal information of more than 10 million people: proactive filing and designation, appointment of a personal information protection officer, an annual social responsibility report, and filing of impact assessment reports. This article reviews the designation criteria, core obligations and implications for AI companies.

EU AI Act Transparency Rules Take Effect: Disclosure and Labelling Duties for Interactive AI

2026.08.03

On 31 July 2026 the European Commission announced that the AI Act would expand its scope from 2 August, applying the transparency rules and the rules for providers of general-purpose AI models. Interactive AI such as chatbots must tell users they are interacting with AI; deepfake content must be labelled and carry machine-readable markings; and obligations for general-purpose AI model providers take effect in parallel. This article reviews the application milestones, core obligations and implications for Chinese companies going global.

The 'Token Economy' and Token Trading: Compliance Observations Behind AI Business-Model Innovation

2026.07.30

In July 2026 the National Data Administration expressly encouraged business-model innovation based on token applications, exploring new trading models such as token trading, cultivating a market consensus of 'paying for quality data', and deepening the integration of token applications with industry, healthcare and finance. This article observes the contract, pricing, data and tax issues that the token economy raises from a compliance perspective.

High-Quality Datasets and the National Integrated Computing Network: How Data Elements Feed AI

2026.07.28

On 28 July 2026 the National Data Administration disclosed at a press conference for the 2026 China International Big Data Industry Expo that 72 industry chain-leader units had built more than 45 PB of high-quality datasets covering over 759 high-value scenarios, and that 1.4 million PFLOPS of intelligent computing power had been connected to the national integrated computing network trial platform. This article reviews progress on high-quality datasets and computing infrastructure and what it means for the supply side of AI companies.

Simplified Measures for Small Personal Information Processors: Streamlined Duties and Cross-Border Exemptions

2026.07.25

On 24 July 2026 the Cyberspace Administration of China issued the Provisions on Simplified Measures for Personal Information Protection by Small Personal Information Processors. The Provisions set streamlined measures for small processors on publishing processing rules, notice and consent, rights response and deletion, and clarify the conditions under which they are exempt from filing a cross-border data security assessment, concluding standard contracts or obtaining certification when providing personal information overseas. This article reviews the identification of applicable entities and the boundaries of the streamlined duties.

'Qinglang' Minors Online Protection: Regulatory Red Lines for AI Content

2026.07.23

In July 2026 the Cyberspace Administration of China deployed a four-month 'Qinglang — Minors Online Protection' special action, whose first phase is the 2026 summer campaign on the online environment for minors. The action focuses on AI 'poison animation' and the hyping of child influencers. This article reviews the regulatory red lines drawn by the special action and what they mean for companies providing AI content and interaction services.

WAIC 2026: Global AI Governance Frameworks and Signals for Companies Going Global

2026.07.21

From 17 to 20 July 2026 the 2026 World AI Conference and High-Level Meeting on Global AI Governance was held in Shanghai. During the conference the World AI Cooperation Organisation was established with its headquarters in Shanghai, and the International AI Ethics Governance Action Plan, the AI Cooperation and Development Action Plan and the Global Cooperation Initiative on Agent Interoperability were released. This article reviews what these outcomes mean for the cross-border compliance of AI companies going global.

China's Interim Measures on Anthropomorphic Interactive AI Services: Scope, Prohibited Content and Assessment Triggers

2026.07.16

The Interim Measures for the Administration of Anthropomorphic Interactive AI Services (Order No. 21 of five departments) took effect on 15 July 2026 — China's first departmental rules dedicated to emotionally companionable AI. The Measures define the scope of anthropomorphic interactive services, set out six categories of prohibited generated content, lay down special rules for minors, and specify when a security assessment is triggered. This article sets out the scope of application, core obligations and compliance arrangements from an enterprise perspective.

On-Device Generative AI Filing: Seven New Registrations and Compliance Points for Handset AI

2026.07.15

On 15 July 2026 the Cyberspace Administration of China announced seven newly filed on-device generative AI services for mobile handsets, including Apple Intelligence. On-device large-model filing has entered a normalised phase. This article reviews how on-device filing differs from cloud filing, the division of duties between model providers and device makers, and the compliance points for on-device products on data localisation, content labelling and minors protection.

'AI + Human Resources and Social Security': Industry Datasets, Corpora and Compliance Boundaries

2026.07.09

On 8 July 2026 the Ministry of Human Resources and Social Security, the National Development and Reform Commission, the Ministry of Industry and Information Technology and the National Data Administration jointly issued the Opinions on Accelerating the Development of 'AI + Human Resources and Social Security' Applications. The document calls for building high-quality industry datasets and AI corpora for the human resources and social security sector, promoting AI in employment, social insurance and labour-relations scenarios. This article reviews the industry-dataset requirements and compliance boundaries relevant to AI companies.

'Qinglang' AI Cleanup, Phase One: Four Problem Categories and Enforcement Priorities

2026.07.07

On 6 July 2026 the Cyberspace Administration of China reported on the first phase of the 'Qinglang — Rectifying AI Application Disorder' special action. Launched in April 2026, the action focuses on failures to perform large-model filing and registration duties, inadequate platform security and content-filtering capability, AI data poisoning, and incomplete implementation of generative-content labelling. This article reviews the four problem categories identified in phase one and what they mean for companies' compliance work.

Overhaul of China's Internet Information Service Measures: The New 'Intelligent Information Services' Section

2026.07.04

On 3 July 2026 the Cyberspace Administration of China re-opened public consultation on the revised draft of the Measures for the Administration of Internet Information Services. The administrative regulation, in force since 2000, is being systematically revised, with two new dedicated sections — 'platform information services' and 'intelligent information services'. This article sets out the institutional points of the intelligent information services section — generative-content labelling, constraints on algorithmic recommendation, protection of workers' rights, and responses to significant security risks — and explains what it means for companies providing AI information services.

MIIT's 2026 Innovation Task Open Call: Four AI Tracks and What Applicants Must Prepare

2026.07.02

In July 2026 the Ministry of Industry and Information Technology launched its 2026 open call for innovation tasks in the industry and information technology field. Under the artificial intelligence heading it set four tracks — foundational technology, application-enabling technology, intelligent products and equipment, and common supporting technology — while the future-industries heading covers five tracks including humanoid robots and embodied intelligence, and brain-inspired intelligence. This article reviews the task layout, the logic of the open-call mechanism, and the compliance groundwork applicants should prepare on intellectual property, data and ethics governance.

'Qinglang' — Cracking Down on Malicious Speculation about Enterprises: Governing AI-Generated False Corporate Information

2026.05.29

On 29 May 2026 the Cyberspace Administration of China issued a notice launching a two-month 'Qinglang — Optimising the Business Online Environment and Rectifying Malicious Speculation about Enterprises' special action. It targets four categories of prominent problem and, for the first time, expressly lists AI-generated false corporate information. This article reviews the action and what it means for AI content producers and companies.

The 2026 Work Points on Digital Literacy and Skills: Fifteen Tasks and AI Literacy

2026.05.29

On 29 May 2026 the Cyberspace Administration of China, the Ministry of Education, the Ministry of Industry and Information Technology and the Ministry of Human Resources and Social Security jointly issued the 2026 Work Points on Improving Digital Literacy and Skills for All, deploying six areas and fifteen priority tasks. Two lines relate directly to the AI sector: improving AI literacy for all, and promoting the safe and standardised development of AI. This article reviews the document and its implications.

2026 Automotive Standardisation Work Points: Mandatory Standards for Autonomous Driving and Data Compliance

2026.05.27

On 27 May 2026 the Equipment Industry Development Centre of the Ministry of Industry and Information Technology released the 2026 automotive standardisation work points. Under 'standards-led action in emerging fields', it calls for accelerating intelligent connected vehicle standards, including mandatory national standards for autonomous driving systems and simulation test methods. This article reviews the points and their meaning for liability boundaries and data compliance.

Three Ministries' Opinion on the Standardised Application and Innovative Development of AI Agents: Nineteen Scenarios and Tiered Governance

2026.05.08

On 8 May 2026 the Cyberspace Administration of China, the National Development and Reform Commission and the Ministry of Industry and Information Technology jointly issued the Opinion on the Standardised Application and Innovative Development of AI Agents, implementing the State Council's 'AI Plus' deployment. It calls for strengthening data security, personal-information protection, permission management and behaviour control for AI agents, and sets out nineteen typical application scenarios and a tiered governance framework. This article reviews the document's key points and what they require of companies.

EU Agreement on the AI Act Omnibus: Banning Deepfake Pornography and Simplifying High-Risk Rules

2026.05.07

On 7 May 2026 the European Parliament and EU member-state representatives reached political agreement on amending the AI Act (the 'AI Omnibus'), agreeing to ban AI systems from generating deepfake pornography, set a clear implementation timetable for high-risk AI rules and simplify innovation-facing rules. This article analyses the parallel 'simplify and draw red lines' approach and what it means for companies going global.

Pirating AI-Generated Short Dramas Leads to a Criminal Conviction: Criminal Protection for AIGC Works

2026.05.07

In May 2026 a judgment in the copyright infringement case brought by the Huangpu District People's Procuratorate of Guangzhou, Guangdong, against Qin and Sha became effective. Without the copyright owner's licence, the two defendants copied and recorded more than 1,700 AI-generated short dramas and sold and distributed them, constituting the crime of copyright infringement; they were sentenced to eight months' imprisonment, suspended for one year and two months, and fined. This article reviews the ruling and the shift from civil enforcement to criminal protection for AIGC works.

The 'Qinglang — Rectifying AI Application Disorder' Special Action: Fourteen Problem Categories and Two-Phase Governance

2026.05.01

On 30 April 2026 the Cyberspace Administration of China issued a notice launching a four-month 'Qinglang — Rectifying AI Application Disorder' special action nationwide, reported in the media from 1 May. The action focuses on fourteen problem categories and proceeds in two phases, the first being the 'Qinglang — Typical Violations in AI Application Services' campaign. This article reviews the governance framework and what the categories mean for companies' self-assessment.

China's First AI Model Infringement Case: Why Model 'Homogeneity' Is Unfair Competition

2026.04.23

On 23 April 2026 details of China's first AI model infringement case were disclosed. The court held that the defendant's special-effect model, formed through data training and tuning, constituted a substantial substitute for the plaintiff's model and caused substantial harm to its competitive interests, amounting to unfair competition, with damages of RMB 1.6 million upheld on appeal. This article reviews the reasoning and competition-compliance points.

Beijing High Court Typical Case: Processing Others' Artwork With AI for Profit Is a Copyright Crime

2026.04.22

On 22 April 2026 the Beijing High People's Court released its 2025 Typical Cases on Judicial Protection of New Quality Productive Forces, including a case on the crime of copyright infringement using AI generative models. The court made clear that AI is not a shield against infringement: using AI to copy and distribute others' original artwork for profit meets the elements of the crime. This article reviews the ruling and the compliance path.

Draft Guide on Data Property-Rights Registration: What a Data 'Identity Document' Means

2026.04.03

On 3 April 2026 the National Data Administration opened public consultation on the Guide on Data Property-Rights Registration (Trial) (draft for comment), covering registration-body management, registration procedures and the use of registration certificates, in order to build a unified national data property-rights registration system. This article reviews the key points and what they mean for AI companies' data-asset management.

NMPA's 'AI Plus Drug Regulation' Implementation Opinions: Seven Directions and Five Foundations

2026.04.02

On 2 April 2026 the National Medical Products Administration issued the Implementation Opinions on 'Artificial Intelligence Plus Drug Regulation' (Guo Yao Jian Zong [2026] No. 6), aiming to build a drug-regulation system integrated with AI by 2030 and setting out seven priority directions for regulatory digitalisation and five foundational tasks. This article reviews the key points and what they mean for pharmaceutical companies and AI service providers.

Ten Ministries' Measures on AI Science-and-Technology Ethics Review: Putting Ethics Into Procedure

2026.04.02

On 2 April 2026 ten ministries including MIIT jointly issued the Measures on AI Science-and-Technology Ethics Review and Services (Trial) (Gong Xin Bu Lian Ke [2026] No. 75), setting out the scope, responsible bodies, working procedures and supervision of AI ethics review, and distinguishing general, simplified, expert re-review and emergency procedures. This article reviews the key points and their practical implications.

'The Copy Was Written by AI' Is No Defence: The Verification Duty of Generative AI Users

2026.03.24

A defamation case in which the defendant argued that 'the video copy was written by AI' has drawn attention. The court held that users of generative AI services bear a duty to verify information when producing and publishing AI-generated content; publishing without citing sources or checking accuracy amounted to infringement. This article reviews the reasoning and the compliance points for content publishing.

AI Face-Swap Drama 'Resembling' a Famous Actor: Liability of Producers and Broadcasters for Portrait Rights

2026.03.20

On 20 March 2026 the Beijing Internet Court reported a portrait-rights case arising from an AI face-swap short drama that 'resembled' a famous actor. The court held that the production company had infringed the actor's portrait rights by using deep-synthesis technology, and that the broadcasting company, having failed to exercise reasonable review, was liable too. This article reviews the ruling and the compliance points for drama producers and platforms.

The Supreme People's Court Work Report on AI: Room for 'Tolerance' and the Boundaries of Liability

2026.03.10

In March 2026 the Supreme People's Court work report stated that courts should 'properly hear AI-related cases and accurately grasp the room for tolerance for technological innovation', citing a case in which a generative AI service erred but the developer had exercised due care and no rights were actually harmed, so no infringement was found. This article reviews the reasoning and companies' due-care checklist.

Data Protection Authorities Issue a Joint Statement on AI-Generated Images and Privacy: A Converging Compliance Baseline

2026.02.23

On 23 February 2026 multiple data protection authorities worldwide jointly issued a statement on artificial intelligence-generated images and privacy protection, responding to the risk that AI image and video generation systems produce identifiable personal content without the individual's knowledge or consent. This article reviews the statement and what it means for image-generation companies.

The CAC's Crackdown on AI Content Lacking Labels: Enforcement Signals from 13,421 Accounts Disposed

2026.02.12

In February 2026 the Cyberspace Administration of China carried out a campaign against accounts that publish AI-generated synthetic information without adding an AI label and use false content to deceive and mislead the public. Some 13,421 accounts were disposed of in accordance with law and agreement, over 543,000 pieces of unlawful information were cleared, and typical cases were reported. This article reviews the enforcement points and directions for corporate self-inspection.

Four Departments Move to Cultivate Data-Circulation Service Institutions: More Traceable Data Sources for AI Companies

2026.02.07

On 7 February 2026 the National Data Administration, the Ministry of Industry and Information Technology, the Ministry of Public Security and the China Securities Regulatory Commission issued the Opinions on Cultivating Data-Circulation Service Institutions and Accelerating the Market-Based Valuation of Data Elements, defining three types of institutions for the first time. This article reviews the key points and what they mean for AI companies' data-source compliance.

China's Live-Streaming E-Commerce Supervision Measures Take Effect on 1 February: Digital-Human Streamers Brought Under Regulation

2026.02.01

On 1 February 2026 the Measures for the Supervision and Administration of Live-Streaming E-Commerce took effect. The measures provide that where live-room operators use figures or videos generated by artificial intelligence and other technologies to conduct live-streaming e-commerce, they must comply with relevant laws and regulations, bringing digital-human streamers and other generated content under regulation. This article reviews the key points and compliance implications for practitioners.

AI at the Central Political and Legal Work Conference: Three Fronts Against AI-Generated Disinformation

2026.01.19

On 18-19 January 2026 the Central Political and Legal Work Conference was held in Beijing. The conference called for cracking down on the use of artificial intelligence to generate and publish disinformation, strengthening research on new technologies, and building digital platforms for political and legal work. This article reviews the AI-related language and what it means for companies.

China's Measures for Certification of Outbound Personal Information Take Effect: A Third Route for Data Export

2026.01.01

On 1 January 2026 the Measures for the Certification of Outbound Personal Information, jointly issued by the Cyberspace Administration of China and the State Administration for Market Regulation, took effect. The measures provide a third compliance route for outbound personal information, alongside security assessment and standard contracts — directly relevant to AI companies that call overseas models or operate across borders.

China's State Security Ministry Issues an AI Safety Notice: Three Rules for Using AI Tools

2025.12.26

On 26 December 2025 China's Ministry of State Security issued a public safety notice on AI tools, flagging the risks of misused deepfake technology and disclosing a case in which an employee's improper use of an open-source AI tool led to internal sensitive material being illegally downloaded by a foreign IP address. This article reviews the notice and the data-security arrangements companies should make.

China's Online Trading Platform Rules Measure: Rule-Making and Enforcement Brought Under Procedural Supervision

2025.12.18

On 18 December 2025 the State Administration for Market Regulation and the Cyberspace Administration of China issued Order No. 116, the Measures for the Supervision and Administration of Online Trading Platform Rules, effective 1 February 2026. The Measures impose procedural requirements on the publication of platform rules, public consultation, consolidation of comments and enforcement. This article reviews the key points for AI service and content platform companies.

UN WSIS+20 Outcome: A People-Centred Digital Future and Tighter AI Safeguards

2025.12.17

On 16 and 17 December 2025 the UN General Assembly held the high-level meeting of the overall review of the implementation of the outcomes of the World Summit on the Information Society (WSIS+20) in New York and adopted an outcome document reaffirming a people-centred, human-rights-based digital future, calling for faster action to close digital divides and highlighting trustworthy governance of data and AI. This article reviews the outcome and what it means for AI companies.

US Executive Order 14365: A Single Federal Rule to Suppress State AI Fragmentation

2025.12.11

On 11 December 2025 the US President signed Executive Order 14365, Ensuring a National Policy Framework for Artificial Intelligence, aiming at a minimally burdensome national AI policy framework and directing the Attorney General to establish an AI Litigation Task Force within 30 days to challenge state AI laws that are unconstitutional, preempted or otherwise unlawful. This article reviews the order and what it means for companies operating in both China and the US.

Korea Targets AI Fake Ads: Labelling Duties and Punitive Damages of Up to Five Times Losses

2025.12.10

On 10 December 2025 Korea's Prime Minister chaired a national policy coordination meeting that released measures against false and exaggerated advertising that uses AI to disrupt market order, requiring labelling of AI-generated material and introducing punitive damages of up to five times losses for knowingly spreading false or fabricated information, alongside 24-hour review and emergency blocking. This article reviews the key points for companies going global.

Brazil Submits an AI National Governance System Bill: The Latin American 'State-Led' Path

2025.12.08

On 8 December 2025 the Brazilian federal government submitted Bill No. 6.237/2025 in an extra edition of the Official Gazette, proposing a National System for the Development, Regulation and Governance of Artificial Intelligence, co-signed by the Ministry of Management and Innovation, the Ministry of Justice and Public Security and the Social Communication Secretariat. The bill advances alongside the Senate's existing AI legislative proposal. This article reviews its orientation for companies going global.

China Consults on the Network Data Security Risk Assessment Measures: Annual Assessment for Important Data Processors

2025.12.06

On 6 December 2025 the Cyberspace Administration of China opened public consultation on the draft Measures for the Administration of Network Data Security Risk Assessment, with comments due by 5 January 2026. Drafted under the Data Security Law and the Network Data Security Management Regulations, the draft would establish an annual risk assessment duty for important data processors and a mechanism for submitting and verifying assessment reports. This article reviews the key points for AI companies.

Shanghai Releases an Open Source System Plan: A Policy Fulcrum for the Open Source Ecosystem

2025.12.05

In December 2025 the Shanghai Municipal People's Government General Office issued the Implementation Plan for Strengthening the Open Source System in Shanghai (Hu Fu Ban [2025] No. 33), targeting an initial open source system by 2027 with one to two internationally influential open source communities, 100 open-source commercialisation companies and more than 200 quality open source projects. This article reviews the key points for AI open source companies.

US Court Orders OpenAI to Produce 20 Million User Chat Logs: Discovery Risk for AI Conversation Data

2025.12.02

On 2 December 2025 the US District Court for the Southern District of New York, in The New York Times v OpenAI, denied OpenAI's motion for reconsideration and held that a sample of 20 million user chat logs is relevant in its entirety and must fall within discovery. The order pushes AI providers' user conversation data into the litigation spotlight. This article reviews the reasoning and what it means for data retention.

China Amends Its Patent Examination Guidelines: Clearer Rules for AI and Big Data Applications

2025.11.13

China's National Intellectual Property Administration issued a decision amending the Patent Examination Guidelines (Order No. 84), retitling section 6 of Chapter 9, Part II to cover invention applications involving algorithm features or business-rule and method features such as AI and big data, refining the examination baseline and adding an exclusion for applications contrary to law or public interest. This article reviews the changes and what they mean for AI patent strategy.

Korea Pre-announces the AI Framework Act Enforcement Decree: Labelling Duties for Generative AI Outputs

2025.11.12

On 12 November 2025 Korea's Ministry of Science and ICT pre-announced the enforcement decree of the Framework Act on AI Development and the Establishment of a Foundation of Trust (Notice No. 2025-970), with a consultation period to 22 December, focusing on labelling of generative AI outputs and duty allocation among responsible parties. The Act took effect on 22 January 2026. This article reviews the key points for companies going global.

611 Services Filed and 306 Registered: The Application-Side Expansion of Generative AI Compliance

2025.11.11

On 11 November 2025 the Cyberspace Administration of China published generative AI service filing information. As of 1 November 2025, 611 generative AI services had completed filing and 306 generative AI applications or functions had completed registration. The parallel growth of filings and registrations shows the compliance focus shifting from the model layer to the application layer. This article reviews the data and the practical points.

India Releases AI Governance Guidelines: The 'Principles First' Path in Emerging Markets

2025.11.05

On 5 November 2025 India's Ministry of Electronics and Information Technology released the India AI Governance Guidelines, setting out a governance framework around safe, trusted, inclusive and accountable AI, with principles on transparency, fairness, accountability, risk assessment and the copyrightability of generative AI outputs. This article reviews the guidelines and what they mean for companies going global.

China Issues Implementation Opinion on 'AI Plus Healthcare': Access, Data and Liability Boundaries

2025.10.20

In October 2025 several Chinese ministries jointly issued an implementation opinion on promoting and regulating 'AI plus healthcare' applications. It targets a group of vertical clinical models for specific diseases by 2027, near-universal AI-assisted primary care and widespread AI-assisted medical imaging diagnosis at secondary hospitals and above by 2030, and an AI application standards system. The compliance boundary for medical AI is becoming clearer.

The Fourth Plenary Session and the 15th Five-Year Plan: Top-Level Design for AI Governance

2025.10.20

From 20 to 23 October 2025 the Fourth Plenary Session of the 20th Central Committee adopted the Recommendations for the 15th Five-Year Plan. The Recommendations treat AI as a focus of digital and intelligent technology innovation and require strengthening AI governance by improving laws, regulations, policy systems, application norms and ethical guidelines — providing the top-level basis for AI legislation.

2025 World Intelligent Connected Vehicle Conference: Standards and OTA Rules Tighten Together

2025.10.16

From 16 to 18 October 2025 the 2025 World Intelligent Connected Vehicle Conference was held. It signalled faster development of standards for combined driving assistance and autonomous driving, stronger production consistency supervision for vehicles with such systems, and tighter rules for over-the-air software updates. The compliance focus in AI-plus-automotive is shifting from features to responsibility.

China Issues Guidance on Deploying AI Large Models in Government: Assistive Positioning and the Confidentiality Line

2025.10.10

In October 2025 China's cyberspace regulator and development planner jointly issued guidance on deploying AI large models in government affairs. It positions government large models as assistive, requires measures against model hallucination, sets a strict confidentiality requirement against inputting classified information into non-classified models, and warns against 'digital formalism'.

China Releases a Batch of AI National Standards: Risk Management, Federated Learning and Beyond

2025.10.05

In October 2025 China's market regulator and standards authority released a batch of AI national standards covering AI risk management capability assessment, federated learning technical specifications, deep learning compiler interfaces, computing centre capability assessment, and general technical requirements for customer-service virtual digital humans. The standards system is extending from 'may we use it' to 'how to use it safely'.

AI Face-Swap Maotai Purchasing Case: Criminal Exposure Runs Along More Than One Line

2025.09.19

In September 2025 a court in Shangyu, Zhejiang, delivered first-instance judgment in a case where defendants used AI face-swap technology to bypass identity verification and buy Maotai liquor. They were convicted of illegally controlling computer information systems and of infringing citizens' personal information. The case shows that misuse of face-swap technology often crosses two criminal lines at once.

China's Supreme People's Court Confirms AI Model Structure and Parameters as Protected Competitive Interests

2025.09.08

In September 2025 the Supreme People's Court released a set of typical unfair competition cases, including one holding that an AI model built through data training and parameter tuning is a protected competitive interest, and that directly using another party's model structure and parameters constitutes unfair competition. The ruling opens a path to protecting AI model assets outside copyright.

China's AI Content Labelling Measures Take Effect: From Rule-Making to Enforcement

2025.09.01

On 1 September 2025 the Measures for Labelling AI-Generated Synthetic Content, jointly issued by four Chinese regulators, took effect, together with the supporting mandatory national standard. Labelling moves from an industry expectation to a legally binding duty, and the responsibilities of service providers and content platforms are now clearly divided. This article reviews the key points and what companies should do.

Japan's AI Promotion Act Fully in Force: East Asia's First Comprehensive AI Statute Takes a Promotion-Led Path

2025.09.01

On 1 September 2025 Japan's Act on the Promotion of Research, Development and Utilisation of AI-Related Technologies came fully into force. The statute puts innovation first, sets out three principles — human-centric, risk minimisation and innovation promotion — and establishes an AI Strategy Headquarters. Its promotion-led approach contrasts with the EU's regulation-led model.

MOT Proposes '1+N+X' Integrated Transportation Large Model Architecture: A Co-Build Path for Industry Models

2025.08.27

On 27 August 2025 the Ministry of Transport outlined the '1+N+X' overall technical architecture for an integrated transportation large model at its regular press conference: '1' is a shared general technical foundation enabling open compatibility with multiple base models and heterogeneous computing power; 'N' is a set of domain models trained on that foundation; and 'X' is agents serving specific business scenarios. The MOT also catalogued 860 typical AI application scenarios, with the first agents to be deployed on the National Integrated Transportation Information Platform.

'General Rules for AI-Assisted Contract Drafting and Review Services' Enters Development: A Standardisation Starting Point for AI Contract Services

2025.08.26

On 26 August 2025 the launch and discussion meeting for the national standardisation guiding technical document 'General Rules for Artificial Intelligence-Assisted Contract Drafting and Review Services' was held at the China National Institute of Standardization. The document, plan number 20251506-Z-469, is administered by the National Technical Committee 264 on Service Standardization (SAC/TC 264) and drafted by bodies including the China National Institute of Standardization and Fatianshi. AI contract services have thus entered a standardisation track.

State Council Issues 'AI Plus' Action Opinion: Three-Phase Goals and Six Priority Sectors

2025.08.26

On 26 August 2025 the State Council issued the Opinions on Deepening the Implementation of the 'AI Plus' Action, setting three-phase goals: by 2027 adoption of next-generation smart terminals and AI agents should exceed 70%, by 2030 exceed 90%, and by 2035 China should fully enter a stage of intelligent economy and intelligent society. The Opinions deploy tasks across six priority sectors and call for strengthened coordination of intelligent computing power.

UK ICO Audits Police Facial Recognition: The Enforcement Direction of Biometric Data Regulation

2025.08.20

On 20 August 2025 the UK Information Commissioner's Office published an audit report on the use of facial recognition by South Wales Police and Gwent Police, covering both live facial recognition and retrospective matching. It is the ICO's latest move in sustained pressure on biometrics, one of the most sensitive AI scenarios, and offers a compliance reference for public bodies deploying facial recognition.

Telecoms Industry AI Development Platform Standards Released: Platform Security Requirements Enter Industry Norms

2025.08.19

On 19 August 2025 a new batch of telecoms industry standards in the YD/T 4392 series was released, including 'General Capability Requirements for Artificial Intelligence Development Platforms - Part 2: Security Requirements' and 'Part 4: Large Model Development and Application', effective 1 December 2025. Security and engineering capability requirements for AI development platforms are entering the industry standards system.

Zhejiang's First AI Commercial-Application Case: Technology Neutrality Is Not Application Neutrality

2025.08.08

On 8 August 2025 the Hangzhou Intermediate People's Court ruled in Zhejiang's first unfair-competition case involving the commercial application of AI. It held that an AI writing tool offering bulk copy generation for social e-commerce 'seed planting' scenarios constituted unfair competition, ordering two internet companies to pay RMB 100,000 jointly. The ruling makes clear that technology neutrality does not equal application neutrality.

State Council Executive Meeting Reviews the AI+ Action Opinion: An Application-First Policy Signal

2025.07.31

On 31 July 2025 the State Council executive meeting reviewed and approved the Opinion on Deepening the Implementation of the AI+ Action. The meeting called for vigorously advancing large-scale, commercialised AI applications, drawing on China's complete industrial system, large market and rich application scenarios, promoting faster adoption and deep integration of AI across the economy and society, and requiring government departments and state-owned enterprises to strengthen their demonstration role.

Shanghai Issues RMB 1 Billion in AI Subsidy Vouchers: A Fiscal Tool for Compute, Models and Corpora

2025.07.28

On 28 July 2025 Shanghai issued Several Measures to Further Expand AI Applications, offering RMB 1 billion in special subsidy vouchers: RMB 600 million in compute vouchers, RMB 300 million in model vouchers and RMB 100 million in corpus vouchers, alongside talent-service measures. The vouchers bring the cost of the three core AI factors directly into the scope of fiscal support, a textbook example of factor-subsidy industrial policy.

WAIC 2025: A Global AI Governance Action Plan and a Cooperation Organisation Proposal

2025.07.26

From 26 to 28 July 2025 the World AI Conference and the High-Level Meeting on Global AI Governance were held in Shanghai. The Chinese government proposed establishing a World AI Cooperation Organisation, with Shanghai as the initial candidate for its headquarters, and the meeting released a Global AI Governance Action Plan setting out 13 concrete actions. It is a moment when AI governance moves from debating rules to building mechanisms.

China's MOHRSS Promotes AI Literacy Continuing Education for Professionals: Ethics and Law Become Required Content

2025.07.24

On 24 July 2025 the General Office of the Ministry of Human Resources and Social Security issued a notice on broadly delivering AI literacy continuing education for professional and technical personnel. The learning content covers technical foundations such as algorithms, compute and data, and expressly includes AI ways of thinking, ethics and law. AI literacy is turning from a specialist skill into a general capability.

Qinglang Campaign Against False Self-Media Information: AI Content Labelling Written into the Requirements

2025.07.24

On 24 July 2025 the Cyberspace Administration of China launched the two-month Qinglang campaign against false information posted by self-media. It expressly targets the use of AI generation and synthesis technology to impersonate others and fabricate false information, and requires that source attribution and AI-generated content labelling be improved — information that should be labelled but is not may not enter the algorithm recommendation pool.

The US Releases Its AI Action Plan: A Federal Route of Deregulation and Export

2025.07.23

On 23 July 2025 the White House released Winning the AI Race: America's AI Action Plan, listing more than 90 federal policy recommendations, and signed several executive orders the same day. The directions include value-based federal AI procurement, promotion of US AI technology-stack exports, and faster permitting for data-centre infrastructure. The centre of gravity of US AI policy has shifted from risk constraint to competitiveness first.

Shenzhen Creates a Special Fund for Open Government AI Scenarios: Moving an Industry with Scenarios and Money

2025.07.21

On 21 July 2025 the Shenzhen Municipal Government Services and Data Management Bureau issued the Operating Rules for the Special Fund for Open Government AI Scenario Applications, effective the same day. The fund provides up to RMB 50 million a year and supports, in graded tiers, companies that build AI applications on open government scenarios. This is the open-scenario-plus-fiscal-funding tool of industrial policy applied concretely to AI.

China Publishes the 12th Batch of Deep Synthesis Algorithm Filings: Routine Filing and the Responsibility of Technical Supporters

2025.07.14

On 14 July 2025 the Cyberspace Administration of China published the twelfth batch of domestic deep synthesis service algorithm filings. The announcement reiterates that providers of deep synthesis services with public-opinion attributes or social-mobilisation capacity must complete filing, change and cancellation procedures under the algorithm recommendation rules, and that technical supporters must do the same by reference. Filing has moved from a one-off registration to routine, batch-based administration.

China's MOE Launches the Digital-Empowerment Teacher Development Action: Staffing and Ethics for AI in the Classroom

2025.07.07

In July 2025 the General Office of the Ministry of Education issued a notice on implementing the Digital-Empowerment Teacher Development Action, making the integrated and innovative use of digital and AI technologies the driver of teacher development. The document implements the education digitalisation strategy and the AI+ agenda in education, and puts teachers' AI capability, content-labelling awareness and ethical norms on the agenda.

Qinglang campaign against online black mouths targeting businesses: where AI-generated corporate information governance begins

2025.05.22

On 22 May 2025 the Cyberspace Administration of China launched a two-month Qinglang campaign to improve the online business environment by tackling so-called black mouths against companies: profit-driven false corporate information, malicious smearing and extortion. AI-generated content has lowered the cost of rumour, making corporate information governance part of the business environment.

Beijing E-Town's city-wide AI district plan: regional competition shifts from subsidies to scenarios

2025.04.27

In April 2025 the Beijing Economic-Technological Development Area issued its 2025 implementation plan for building a city-wide artificial intelligence district, introducing a 'one model, one plan; one industry, one policy' mechanism. By the end of 2025 it aims to open 100 landmark application scenarios, cluster 600 core companies in the industry chain and exceed RMB 80 billion in industry scale. The centre of gravity in local AI policy is moving from cash subsidies to scenario supply.

The Politburo's collective study on AI: a top-level signal that development and regulation go together

2025.04.25

On 25 April 2025 the Political Bureau of the CPC Central Committee held its twentieth collective study session on strengthening the development and regulation of artificial intelligence. The session stressed self-reliance and an application-oriented approach, called for AI to develop in a healthy and orderly way in a beneficial, safe and fair direction, and pointed to the advantages of the new system for mobilising resources nationwide.

Nine departments on accelerating education digitalisation: AI in schools moves from pilot to system

2025.04.15

In April 2025 the Ministry of Education and eight other departments jointly issued the Opinion on Accelerating Education Digitalisation (Jiao Ban [2025] No. 3). It is the first time education digitalisation has been issued jointly by nine departments, bringing the use of AI in teaching, management and assessment under a single deployment and writing data security and platform standards into the same document.

Beijing's action plan for software firms' AI application capability: compute vouchers and agent support

2025.04.08

On 8 April 2025 the Beijing Municipal Bureau of Economy and Information Technology issued its 2025 action plan to support information software companies in strengthening AI application service capability, setting out eight measures. Support of up to RMB 30 million applies respectively to MaaS platform compute deployment cost, non-hardware procurement for industry models and the first listing of general-purpose agents.

Shenzhen's operating rules for AI pioneer city support: model vouchers and demonstration benchmarks

2025.03.19

In March 2025 the Shenzhen Municipal Bureau of Industry and Information Technology issued operating rules for the AI pioneer city project support programme, covering compute support, foundational data, AI software, AI products and AI services. Ten projects are supported, including model vouchers, industry application demonstration benchmarks and domestic AI ecosystem source innovation centres, on a post-hoc reward basis.

The tenth batch of deep synthesis algorithm filings: the boundaries and rhythm of the filing duty

2025.03.12

On 12 March 2025 the Cyberspace Administration of China published the tenth batch of domestic deep synthesis service algorithm filings. Citing the Provisions on the Administration of Deep Synthesis of Internet Information Services, the notice restates that providers of deep synthesis services with public opinion attributes or social mobilisation capacity must complete filing, change and cancellation procedures, with technology providers following by reference.

AI Plus in the 2025 government work report: from phrasing to deployment

2025.03.05

On 5 March 2025 the government work report proposed continuing to advance the AI Plus initiative, stressing that digital technology should be better combined with manufacturing and market advantages and that wide application of large models should be supported. It also deployed next-generation intelligent terminals such as intelligent connected new energy vehicles, AI phones and computers and intelligent robots, as well as intelligent manufacturing equipment.

The national public data registry platform goes live: an institutional entry point for AI training data

2025.03.01

On 1 March 2025 the national public data resource registry platform officially went into operation, and the interim measures on the administration of public data resource registration took effect at the same time. The platform adopts a one-standard, two-tier architecture, with the national platform and provincial platforms carrying out registration work in coordination, providing a basis for confirming rights in and circulating public data resources.

China's personal information compliance audit measures: the 10 million threshold and a two-year cycle

2025.02.14

In February 2025 the Cyberspace Administration of China published measures on personal information protection compliance audits, effective 1 May 2025. Processors handling personal information of more than 10 million people must carry out a compliance audit at least once every two years; where a security incident affects over one million people, regulators may require an audit by a professional institution.

The opinion on high-quality development of the data labelling industry: policy on the training-data supply side

2025.01.13

On 13 January 2025 the National Development and Reform Commission and other departments issued an opinion on promoting the high-quality development of the data labelling industry, calling for key technology work on cross-domain and cross-modal semantic alignment, 4D labelling and large-model labelling, and supporting intelligent tools for multimodal labelling, label review and quality assessment.

Beijing's eight departments issue a science and technology ethics opinion: a 'Beijing approach' to AI ethics

2025.01.03

In January 2025 eight Beijing departments, including the municipal science and technology commission, issued trial implementation opinions on strengthening science and technology ethics governance. Anchored in Beijing's role as an international centre for science and technology innovation, they explore a 'Beijing approach' to ethics governance in artificial intelligence and biomedicine.

← 返回首页