On 19 May 2025 the Cyberspace Administration of China published the eleventh batch of domestic deep synthesis service algorithm filings. With eleven consecutive batches published, filing has moved from a new regime to a routine step.
The three moves in the filing regime
The notice restates the basic framework: a provider’s obligations are not limited to initial filing but include change filing and cancellation filing. Adjustments to algorithm logic, discontinuation of a service or a change in entity information can each trigger a further obligation.
Filing is therefore not a one-off certificate but a ledger that has to be maintained. A company’s compliance cost arises mainly when something changes, not when the first submission is made.
What “by reference” means for technology providers
The notice states that technology providers for deep synthesis services should complete filing by reference. That wording widens the class of obligated parties: not only providers of synthesis services facing users directly, but also the technical parties supplying 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 deep synthesis filing in practice and 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 all obligations are covered. See our notes on large model filing and on generative AI filing and registration.
Where companies can start
First, build a trigger list for changes to filing information, identifying which internal changes require the filing to be updated.
Second, check the company’s role in the chain — provider, technology provider, or both.
Third, add filing status to the product launch checklist, so that services are not launched before filing is complete. See our notes on the twelfth batch and the thirteenth batch of deep synthesis algorithm filings.
The eleventh batch also confirms something about rhythm: filings are now published at a steady interval, and a company that treats the exercise as a one-off project rather than a maintained record will eventually fall out of step with it.
The value of filing is not the submission itself but the way it forces a company to set out clearly its algorithm capability, its service boundary and the responsible entity.
This article is based on the Cyberspace Administration of China’s notice on the eleventh batch of domestic deep synthesis service algorithm filings and public information and is for reference only; it does not constitute legal advice.