On 12 March 2025 the Cyberspace Administration of China published the tenth batch of domestic deep synthesis service algorithm filings. With ten batches published in succession, deep synthesis algorithm filing has settled into a stable disclosure rhythm.
Filing is not a one-off act
The notice restates the basic framework of the regime: what a provider must do is not limited to initial filing, but also includes change filing and cancellation filing. Adjustments to algorithm logic, discontinuation of a service or a change in entity information can each trigger a subsequent obligation.
See our notes on filing and registration in practice: the compliance cost of filing arises mainly when something changes, not when the first submission is made.
The scope of obligated parties
The notice makes clear that providers of deep synthesis services with public opinion attributes or social mobilisation capacity should complete filing procedures, and that technology providers for deep synthesis services should complete them by reference. The “by reference” wording extends the scope of obligation to the technical parties that supply synthesis capability to others.
For AI companies that output capability in API or SDK form, this is a point to check carefully. See our notes on algorithm filing.
How it divides work with generative AI filing
Deep synthesis filing and generative AI service filing are two parallel regimes with different objects and triggers, but they overlap. A common mistake is to complete one and assume that all obligations are covered.
See our notes on the difference between large model filing and registration, and the eleventh and twelfth batches that followed.
Where companies can start
First, build a trigger list for changes, setting out which internal changes require the filing to be updated in step.
Second, check the company’s role in the chain and decide whether it is a provider, a technology provider, or both.
Third, add filing status to the product launch checklist, so that services are not launched before filing is completed. See our notes on generative AI filing and registration.
The continuous publication of ten batches shows that the regime is running steadily. The test for companies has shifted from knowing that filing is required to maintaining a filing over time.
This article is based on the Cyberspace Administration of China’s notice on the tenth batch of domestic deep synthesis service algorithm filings and public information and is for reference only; it does not constitute legal advice.