China introduced interim measures for certain generative AI services in August 2023. The rules are not a universal statement about every offline experiment or foreign service; their defined scope and other applicable laws matter.
What the official measures establish
The Cyberspace Administration of China and other authorities published the Interim Measures for the Management of Generative Artificial Intelligence Services in July 2023, effective 15 August 2023. The text addresses services using generative technologies to provide generated text, images, audio or video to the public within its defined scope. It describes service providers and users and addresses lawful content, personal information and service security.
Avoid overbroad geographic claims
Do not claim that every model trained anywhere in the world must satisfy identical registration or labeling requirements. The legal assessment depends on whether the service is offered within the regulated context, the operator’s role, the data processed and other Chinese rules. Technical connections and residency choices also require separate review.
Practical compliance questions
Identify whether the activity is a public generative AI service or an internal research arrangement, who operates the interface or API, what data is used, what output controls and complaint mechanisms exist, and whether additional filing, security or licensing rules apply. Use authoritative Chinese-language text and qualified local interpretation for formal compliance.
Content and data obligations
Content policies, privacy protection, authenticity and risk management are addressed in the measures. User-facing outputs are not automatically lawful merely because generated by a registered tool. Maintain moderation, traceability and responsive corrections appropriate to the service, and audit changes to applicable requirements.
Separate subsequent regulation
China adopted distinct labeling measures effective 1 September 2025 for applicable synthetic content. Those are not retroactive features of the original 2023 measures. A cross-border product needs a timeline that recognizes each instrument’s publication and application dates.
Caveat
This is an English explanatory summary grounded in the original CAC text, not an official translation or a legal opinion. Where a word in translation affects obligations, the authoritative Chinese legal text prevails.
Sources & Further Reading
- Interim Measures for Generative AI Services — CAC China.
- Measures for labeling AI-generated synthetic content — CAC China.
Guidance varies by jurisdiction and application. This is general education, not legal, medical or other professional advice.