What algorithm filing is, and which companies must comply
Algorithm filing is the mandatory registration regime that China applies to providers of algorithmic recommendation services “with public-opinion attributes or the capacity for social mobilisation”. It is established under Article 24 of the Provisions on the Administration of Internet Information Service Algorithmic Recommendations (Order No. 9 of the CAC and three other authorities, effective 1 March 2022).
Statutory text:
A provider of algorithmic recommendation services with public-opinion attributes or the capacity for social mobilisation shall, within ten working days from the date on which it begins providing services, file through the internet information service algorithm filing system the name of the provider, the form of service, the field of application, the type of algorithm, the algorithm self-assessment report, the content proposed for publication, and other information, and complete the filing formalities.
Product types that must file:
| Product type | Legal basis | Typical scenarios |
|---|---|---|
| Recommendation algorithms | Provisions on Algorithmic Recommendations | Content, product and advertising recommendation |
| Generative AI services | Article 17, Interim Measures for Generative AI | Large language models, AI image generation, AI video generation |
| Deep synthesis services | Article 19, Provisions on Deep Synthesis | Face swapping, voice cloning, virtual humans |
| Large models (self-developed or fine-tuned) | Interim Measures for Generative AI | Models above the parameter threshold must separately complete large-model filing |
What counts as “public-opinion attributes or the capacity for social mobilisation”?
The following are generally treated as meeting the test:
- Services that can synthesise, generate or push news, commentary or social media content
- Text-generation functions such as chat, question answering or writing that output content to unspecified users
- The ability to generate images, audio, video or other deep synthesis content
- Monthly active users above a certain scale
- Interactive functions such as public discussion, comments or bullet comments
The filing process in five steps
Step one: account registration (one day)
- Open the internet information service algorithm filing system at https://beian.cac.gov.cn
- Click “Register” in the top right corner
- Enter the handler’s mobile number, verification code and login password
- Enter the handler’s name and a corporate email address (a corporate address is required; personal addresses risk rejection)
- Accept the user agreement and complete registration
Points to note:
- The corporate email address receives review notifications and is therefore critical
- One corporate email address may register only one account
- The handler should preferably be the legal, compliance or product lead
Step two: entity filing (three to seven working days)
Once registered, the entity itself must be filed first, with the following information:
| Category | Details |
|---|---|
| Basic entity information | Company name, unified social credit code, registered address |
| Certificate information | Scanned business licence (with company seal) |
| Legal representative | Name, identity card number, contact details |
| Algorithm security officer | Name, position, contact details |
| Algorithm security department | Description of the organisational structure |
Provincial CAC offices generally complete entity review within three to seven working days.
Step three: algorithm filing disclosure (five to ten days of preparation)
Once entity filing is approved, the algorithm itself must be disclosed. This is the most time-consuming preparatory stage, and requires:
- Algorithm name, for example “XX recommendation algorithm” or “XX generative large model”
- Algorithm description: basic principles, operating logic and technical architecture
- Application scenario: the product and function in which the algorithm is used
- Algorithm type: generative synthesis, personalised push, ranking and selection, retrieval and filtering, or scheduling and decision-making
- Algorithm self-assessment report, covering data security, model security, content compliance, user rights, risk prevention and emergency response
- Content proposed for publication: the basic algorithm information to be disclosed to the public
Step four: document review (thirty working days)
After submission, the national and provincial CAC authorities review the documents.
Statutory requirement:
Where the documents are complete, filing shall be granted within thirty working days, a filing number issued and the filing published; where the documents are incomplete, filing shall not be granted, and the filer shall be notified within thirty working days with reasons given.
In practice:
- Complete documents without issues: approximately two to four weeks
- Documents returned for amendment: each return adds two to four weeks
- Among agency cases, roughly 70% pass first review, while 30% are returned at least once
Step five: issuance and display of the filing number
Once filing is complete:
- The algorithm filing number is issued
- The number must be displayed conspicuously on the website or application through which services are provided
- A link to the published information must be provided
Statutory requirement:
A provider of algorithmic recommendation services that has completed filing shall display its filing number in a conspicuous position on the website, application or other channel through which it provides services to the public, and provide a link to the published information.
The four core document sets
Set one: entity qualification documents
- Scanned business licence or legal person certificate (with company seal)
- Identity document of the legal representative
- Identity document of the algorithm security officer
- Description of the organisational structure of the algorithm security department
- Letter of authorisation for the contact person, where the legal representative is not handling the matter directly
Set two: core algorithm documents
- Algorithm description document: name, version, type, application scenario, operating environment, data sources and business logic, together with an architecture diagram showing the full data flow
- Algorithm security self-assessment report (the most important and most time-consuming item):
- Data security: lawfulness of data sources, data classification and grading, security of storage and transmission
- Model security: training security, output security, resistance to attack
- Content compliance: interception of unlawful content, review workflow
- User rights: the right to be informed, the right to choose, the right to refuse
- Risk prevention: identification, assessment and handling mechanisms
- Emergency response: contingency plans and handling procedures
Set three: operational and risk-control documents
- Documented manual content review mechanism
- Complaints and reporting handling rules
- Contingency plan for algorithm security incidents
- Rules on content protection for minors
- Specifications for traceability and labelling of AI-generated content
Set four: system attachments
- Algorithm Filing Undertaking
- Statement on Implementation of the Primary Responsibility for Algorithm Security
- Content Proposed for Publication
- Other supporting documents required by the system
Typical timeline
| Stage | Statutory or practical duration | Notes |
|---|---|---|
| Account registration | One day | Data entry only |
| Entity filing | Three to seven working days | Reviewed by the provincial CAC office |
| Document preparation | Two to four weeks | The most time-consuming stage, particularly the self-assessment report |
| Algorithm filing review | Thirty working days by statute | Two to four weeks in practice, where matters proceed smoothly |
| Return for amendment | Two to four weeks per return | Around 30% of cases are returned at least once |
| Total | Two to three months | Where matters proceed smoothly; three to five months with returns |
Consequences of launching without filing
Penalty ladder
| Severity | Measure | Legal basis |
|---|---|---|
| Minor | Warning, public criticism, rectification within a deadline | Article 29, Provisions on Algorithmic Recommendations |
| Moderate | Fine of RMB 10,000 to 100,000, suspension of information updates, suspension of algorithm services | Articles 29 and 31, Provisions on Algorithmic Recommendations |
| Serious | Removal across all channels, shutdown of services, revocation of relevant qualifications | Article 32, Provisions on Algorithmic Recommendations |
| Fraudulent filing | Revocation of filing, fine of RMB 10,000 to 100,000 | Article 33, Provisions on Algorithmic Recommendations |
Enforcement in practice
Case one: the Chongqing “wrapped AI” penalties (2024) Two AI question-and-answer tools, “Lingxiang Zhiwen AI” and “Shaobing Tuozhan Mi”, operated without any large-model filing or registration and called overseas model APIs directly to serve domestic users for a fee. Each was fined RMB 30,000 and RMB 50,000 respectively, ordered to shut down its official domain permanently, and the operating companies were placed on the CAC’s priority supervision list.
Case two: removal of a voice-cloning application (2024) “Reecho”, an AI voice-cloning tool that allowed unrestricted cloning of public figures’ voices, had no filing or registration record. It was removed simultaneously from app stores and mini-programs nationwide, with a deadline imposed for completing filing, registration and security review.
Case three: the Shanghai “Liangjian Pujiang” enforcement action (2025) The Shanghai CAC office’s “Liangjian Pujiang 2025” action found three generative AI service websites that had failed to conduct security assessments, resulting in content such as “face swapping and voice changing” and “disguise and fabrication”. This was the first case in which the Interim Measures for the Administration of Generative AI Services were applied as the basis for penalties.
After filing
- Change of filing: changes to algorithm information must be filed within ten working days of the change
- Cancellation: where services cease, cancellation must be filed within twenty working days
- Annual self-inspection: at least one algorithm security self-inspection is recommended each year
- Display of the filing number: the number must be displayed continuously and conspicuously on the website and app
Frequently asked questions
Q: Who is responsible for algorithm filing on a SaaS platform? A: Both the API provider and the API user may need to file, depending on the technical architecture and business model. Where a company merely calls the API of an already-filed large model without altering model parameters, large-model registration rather than large-model filing is usually required, but algorithm filing still applies.
Q: May a product go live while filing is in progress? A: Strictly speaking, it should go live only after filing is complete. In practice some products adopt a “soft launch with filing in parallel”, but this carries enforcement risk.
Q: What is the difference between algorithm filing and large-model filing? A: Algorithm filing covers algorithm services at the application layer, while large-model filing covers self-developed or heavily fine-tuned model foundations. The two are not interchangeable, and some business models require both. See large-model filing versus registration.
Q: Is filing required to deploy an open-source model? A: Where an open-source model is deployed and used to provide services to unspecified users, both algorithm filing and large-model filing are required. Where it is used only for internal testing, filing is generally not required.
This article is prepared on the basis of the Provisions on the Administration of Internet Information Service Algorithmic Recommendations, the Interim Measures for the Administration of Generative Artificial Intelligence Services, the Provisions on the Administration of Deep Synthesis of Internet Information Services and other regulations in force. Specific practice should follow the actual requirements of the beian.cac.gov.cn system. For full-service assistance with algorithm filing, please contact Geason Law Offices.