On 11 November 2025 the Cyberspace Administration of China (CAC) published generative AI service filing information. As of 1 November 2025, 611 generative AI services had completed filing and 306 generative AI applications or functions had completed registration. The notice reiterated that entities providing generative AI services with public-opinion attributes or social mobilisation capacity should complete filing or registration with the local cyberspace authority.
What the two numbers show
Filing corresponds to “services”, registration to “applications or functions”. The gap between 611 and 306 reflects the structure between the model layer and the application layer: one filed underlying service may support multiple registered applications or functions.
Growth on the application side is the trend to watch. When the number of underlying services stabilises while registered applications and functions keep growing, the commercial centre of gravity is shifting from “training models” to “landing scenarios”. For companies, that means the compliance focus expands from “model filing” to “whether each public-facing application function is registered”.
Three common misconceptions
First, that using a third-party model already filed removes the need to register. Filing targets the service provider; registration targets the specific application or function. A company building a public-facing application on a third-party model must still assess whether it is an entity subject to registration. See our note on filing and registration in practice.
Second, that only large platforms need to file. The test is whether the service is provided to the public with public-opinion attributes or social mobilisation capacity — it does not depend on company size. Vertical AI customer service, AI writing and AI companion products may fall within scope.
Third, that filing is a one-off act. When service scope, functional modules or the operating entity change, filing and registration information must be updated.
The trend behind the data
From the start of the year to the end, generative AI filings and registrations grew steadily. By the end of 2025 the cumulative filing number rose further, with a substantial annual increase, showing filing has entered routine operation. See our notes on the 2025 filing data and 2026 filing data.
For companies preparing to launch AI products, the recommendation is to treat “do we need to file or register” as a project-initiation question rather than a last-minute fix. See our algorithm filing service.
Growth in filing data ultimately reflects generative AI moving from technical exploration to scaled application. And every step of scaled application corresponds to a compliance obligation that must be discharged.
This article is based on the CAC’s generative AI service filing notice and public information. It is for general reference only and does not constitute legal advice.