On 6 November 2025 the Cyberspace Administration of China (CAC), acting under the Provisions on the Administration of Deep Synthesis of Internet Information Services, published the 14th batch of domestic deep synthesis service algorithm filings.
What the steady batches mean
Deep synthesis algorithm filing has been published in successive batches since the Provisions took effect. The ability to release batches on a regular schedule shows the mechanism has completed its transition from a one-off clean-up to routine administration.
For companies, routine administration means two things: filing is no longer a periodic enforcement campaign but an ongoing market-access condition; and because filing information is public, competitors, customers and regulators can all verify a company’s compliance status, which narrows the room for “filed but not real”.
Filing versus registration
In practice, companies often conflate “algorithm filing” and “generative AI service filing”. Their objects differ.
Deep synthesis algorithm filing targets the algorithm used to provide a deep synthesis service, under the Provisions on Deep Synthesis. Generative AI service filing targets entities providing generative AI services to the public, under the Interim Measures. The former focuses on the algorithm, the latter on the service. See our note on filing and registration in practice.
Four self-inspection questions
First, is the algorithm within scope? Any product offering face generation, face swapping, voice synthesis or text-to-image features should check whether an algorithm filing has been completed.
Second, does the filing match reality? A mismatch between the algorithm name, the application product and the functional description and actual operations is a high-frequency issue in inspections.
Third, is the filing status still valid? After algorithm iteration, product renaming or feature expansion, change formalities should be completed promptly. See the 15th and 16th batch notes.
Fourth, is it aligned with content labelling? Deep synthesis services are also subject to the Measures for Labelling AI-Generated Synthetic Content. Filing compliance is not labelling compliance; both tracks must be advanced together. See our note on labelling enforcement.
Filing is not the finish line
Treating filing as the finish line is a common mistake. Filing answers “may we provide the service”; corpus security, content safety, labelling and minor protection answer “is the provision compliant”. See our algorithm filing service.
For generative AI companies, making filing management a continuous internal process — rather than a one-off submission — is the basic discipline for routine regulation.
This article is based on the CAC’s 14th batch of deep synthesis service algorithm filings and public information. It is for general reference only and does not constitute legal advice.