On 17 March 2026 the Cyberspace Administration of China (CAC) published its announcement of filed generative AI services. As of 28 February 2026, 796 generative AI services had completed filing and 481 generative AI applications or functions had completed registration; 48 new services were filed in January and February 2026.
Two numbers, two pathways
The most notable feature of the announcement is that “796 filed services” sits alongside “481 registered applications”. This shows the regulator has clearly split generative AI compliance into two pathways: service filing and application or function registration.
The difference lies in the entity’s role and public-opinion attributes. Providers of generative AI services with public-opinion attributes or social-mobilisation capacity must file; those offering services based on an already-filed model, or providing a specific application function, typically register. The logic for choosing a pathway is set out in our note on filing vs registration for large models.
Three trends behind the data
First, growth has stabilised. At 48 new filings in January and February, averaging about 24 a month, the pace has levelled off compared with earlier peaks. This usually means existing entities have largely completed first-time filing and the industry has entered a phase of “maintaining the stock plus onboarding new entrants”.
Second, registrations approach 60% of filings. The application layer is spreading quickly while filing entities remain relatively concentrated — consistent with an industry structure of “concentrated models, dispersed applications”.
Third, local batches are the norm. Receipt is handled by local cyberspace authorities and local batch announcements continue, as we describe in our note on the May local batches.
Three practical points for applicants
First, choose the pathway before preparing materials. Filing and registration require different materials, and misjudging the pathway significantly extends the timeline.
Second, make the model’s provenance clear. Providing services based on a third party’s already-filed model differs from filing a self-developed model, and the upstream compliance status must be explained.
Third, assess feature changes. Adding generative capability, widening use scenarios or changing the degree of public exposure may all trigger reassessment — see our note on MIIT’s action to cultivate AI application service providers.
As filing and registration become routine, the room for “launch first, file later” narrows. For AI companies, moving the filing milestone into product planning is cheaper than rushing materials before launch. See our algorithm filing service.
This article is based on the CAC’s announcement of filed generative AI services published on 17 March 2026. It is for general reference only and does not constitute legal advice.