On 7 January 2026 the Cyberspace Administration of China (CAC) published the fifteenth batch of domestic deep-synthesis service algorithm filings. Relevant parties can check the details through the internet information service algorithm filing system. This is the fifteenth public release since the filing system was established under the Provisions on the Administration of Deep Synthesis of Internet Information Services.
What routine filing means
From the fourteenth to the fifteenth batch and beyond, algorithm filing has settled into a stable release rhythm. Two consequences follow.
First, filing is no longer “the last step before launch” but a state that runs through the product lifecycle. Where algorithm functions, application scenarios or service forms change materially, filings often need to be amended or cancelled.
Second, the public nature of filing information means the risk of “launching without filing” has risen significantly. Filing information is publicly searchable, so competitors, users and regulators can check it.
Which algorithms need filing
Under the Provisions on the Administration of Algorithm Recommendations for Internet Information Services and the Provisions on Deep Synthesis, two categories require filing: algorithm recommendation services with public-opinion attributes or social mobilisation capability, and services providing deep-synthesis functions. In practice, text generation, image generation, speech synthesis, video generation, face generation and swapping, and virtual-scene generation may all fall within deep synthesis.
Note that algorithm filing and generative AI service filing are different routes: the former targets the “algorithm” and is managed through the algorithm filing system, while the latter targets the “service” and is handled by local cyberspace authorities. See our note on the sixteenth batch and the filing rhythm and our algorithm filing service.
Self-inspection checklist
Is entity information consistent with the business licence? Entity name, unified social credit code and legal representative must stay in sync with registration information, and changes updated promptly.
Are algorithm names and functional descriptions accurate? Descriptions should reflect actual functions, avoiding both vague wording and mismatch with actual capability.
Do filings cover all launch channels? Where the same algorithm is used across multiple apps, mini-programs or web pages, confirm the filing covers all channels.
Are mechanism explanations and security assessment reports retained? Deep-synthesis providers must retain relevant materials as required.
Is synthetic-content labelling implemented? Filing is the entry point; labelling is an ongoing duty. See our note on synthetic-content labelling enforcement.
Recommendation
Companies should keep an algorithm inventory ledger recording name, filing number, launch channels, change history and responsible person, with periodic review. Those providing generative AI services should also maintain service filing information. See our note on local filing batches.
Once filing is routine, the real risk is not whether a filing was once made, but whether filing information stays consistent with the business as it is.
This article is based on the CAC’s fifteenth batch of deep-synthesis service algorithm filing announcement and public information. It is for general reference only and does not constitute legal advice.