Information date: 30 October 2026 — Under the Interim Measures for Generative AI Services, in force since 15 August 2023, a service offered to the Chinese public that can shape public opinion or mobilise social behaviour must pass a security assessment and complete algorithm filing with the Cyberspace Administration of China. A foreign-invested provider files through the provincial CAC bureau and submits model documentation, corpus provenance and content-moderation evidence. If you will serve Chinese users directly, budget three to six months and complete filing before launch. If you reach those users only through a licensed domestic partner, put filing responsibility, content liability and audit rights into the contract. If the deployment is employee-only, write a short internal-use exemption memo and keep it on file.
Verified facts and scope
Under the Interim Measures for Generative AI Services, in force since 15 August 2023, a service offered to the Chinese public that can shape public opinion or mobilise social behaviour must pass a security assessment and complete algorithm filing with the Cyberspace Administration of China. A foreign-invested provider files through the provincial CAC bureau and submits model documentation, corpus provenance and content-moderation evidence.
Scope has to be fixed before the numbers mean anything: Covers consumer and enterprise services delivered to users in mainland China by app, mini-program, web portal or resold API. Purely internal tools, closed research environments and outbound-only services sit outside the filing duty, but the exemption has to be documented. Pre-check: who holds the ICP filing, whether the model is self-developed or licensed from an overseas vendor, and who owns the user data. Anything outside that set is a separate question with its own evidence requirement, and mixing the two is the most common way a workable plan turns into an unusable one.
For a decision on “Guide: Filing a Generative-AI Service With CAC — Algorithm Filing, the Security-Assessment Pack and the Content-Moderation Evidence a Foreign-Invested Provider Must Hold”, keep three layers apart: the published rule or statistic, the company’s own orders and process records, and the assumptions nobody has tested yet. The first layer defines the external conditions, the second proves what is true for this business, and the third is where the risk actually sits. Public material cannot substitute for a contract, a system log, a sample or a live test.
A practical way to test the scope is to ask which parts of “Guide: Filing a Generative-AI Service With CAC — Algorithm Filing, the Security-Assessment Pack and the Content-Moderation Evidence a Foreign-Invested Provider Must Hold” would still be true if the company changed supplier, entity or product line tomorrow. Items that survive that change belong to the rule layer and can be taken from official publications; items that do not survive belong to the operating layer and have to be rebuilt from invoices, warehouse records, customs entries or platform statements. Where Covers consumer and enterprise services delivered to users in mainland China by app, mini-program, web portal or resold API. Purely internal tools, closed research environments and outbound-only services sit outside the filing duty, but the exemption has to be documented. Pre-check: who holds the ICP filing, whether the model is self-developed or licensed from an overseas vendor, and who owns the user data, the two layers are frequently mistaken for each other, and an action plan built on the wrong one either over-complies or misses a deadline it never saw coming.
How the effect reaches operations
Filing attaches to the algorithm rather than to the company. The 2022 algorithm-recommendation rules require disclosure of how the mechanism works and where the data comes from, while the 2023 measures add lawful training data, synthetic-content labelling and a working complaint channel. Moderation evidence exists to show the service can detect and block prohibited output within a stated response time.
Treating filing as a one-off and never re-filing after a material model change; routing prompts to an overseas API, which raises a separate cross-border data question; promising factual accuracy in marketing copy that regulators then read as a binding service commitment; and submitting a moderation policy with no logs, staffing or escalation record behind it.
Translated into an operating sequence, Filing attaches to the algorithm rather than to the company. The 2022 algorithm-recommendation rules require disclosure of how the mechanism works and where the data comes from, while the 2023 measures add lawful training data, synthetic-content labelling and a working complaint channel. Moderation evidence exists to show the service can detect and block prohibited output within a stated response time. That ordering matters: check applicability first, then the transmission step, and only then the size of the gap in cost or timing. When an intermediate step cannot be confirmed, the honest response is to narrow the scope of the conclusion rather than to substitute an industry average for the company’s own figures.
The cost of getting the order wrong is asymmetric. A team that checks applicability too late usually discovers it at the point where the shipment, the filing or the invoice can no longer be changed without penalty, and by then the only remaining lever is price. A team that checks early spends a few hours on questions that turn out to be irrelevant, which is cheap by comparison. On “Guide: Filing a Generative-AI Service With CAC — Algorithm Filing, the Security-Assessment Pack and the Content-Moderation Evidence a Foreign-Invested Provider Must Hold” the practical rule is therefore to spend the first hour on scope and the second on the numbers, never the other way round.
Decision
If you will serve Chinese users directly, budget three to six months and complete filing before launch. If you reach those users only through a licensed domestic partner, put filing responsibility, content liability and audit rights into the contract. If the deployment is employee-only, write a short internal-use exemption memo and keep it on file.
The conditions should be written down so the decision can be re-run by someone else: Covers consumer and enterprise services delivered to users in mainland China by app, mini-program, web portal or resold API. Purely internal tools, closed research environments and outbound-only services sit outside the filing duty, but the exemption has to be documented. Pre-check: who holds the ICP filing, whether the model is self-developed or licensed from an overseas vendor, and who owns the user data. When those hold, proceed as described; when one is missing, close the gap first and decide afterwards. Summarises published filing requirements for planning purposes only; it is not a compliance opinion on your model, and CAC practice and documentation expectations vary by province and by service type.
Two workstreams usually have to move in parallel. The compliance workstream closes the document side of “Guide: Filing a Generative-AI Service With CAC — Algorithm Filing, the Security-Assessment Pack and the Content-Moderation Evidence a Foreign-Invested Provider Must Hold” — registrations, confirmations, filings — while the commercial workstream protects the delivery date, the pricing already quoted and the customer commitments that were made on the earlier reading of the rules. Running them as one queue is how small documentation gaps become missed shipment dates: the commercial side waits for a certificate that could have been requested a week earlier. If you will serve Chinese users directly, budget three to six months and complete filing before launch. If you reach those users only through a licensed domestic partner, put filing responsibility, content liability and audit rights into the contract. If the deployment is employee-only, write a short internal-use exemption memo and keep it on file. Set one owner per workstream and one shared status sheet, and treat a red item on either side as a reason to freeze only the affected order.
Implementation checklist
- Confirm which legal entity holds the ICP filing first.
- Assemble corpus provenance and labelling records before drafting.
- Write the moderation SOP against a measurable response time.
- Name one decision owner, one execution owner and one review date.
- Keep the source page, access date, entity and internal evidence.
- On any change, reopen only the affected judgement.
Evidence and review
Start with the smallest test that can change the answer: Confirm which legal entity holds the ICP filing first. Pick one real entity or one representative case, write down the continue, watch and stop conditions in advance, and record the input version, the owner, the start time and the actual result. The first pass should only look at facts that move the decision; formatting preferences are not risk.
The second pass is completed by “Assemble corpus provenance and labelling records before drafting”, and someone who did not prepare the file should spot-check one piece of critical evidence. Treating filing as a one-off and never re-filing after a material model change; routing prompts to an overseas API, which raises a separate cross-border data question; promising factual accuracy in marketing copy that regulators then read as a binding service commitment; and submitting a moderation policy with no logs, staffing or escalation record behind it. A single small deviation can be corrected in place; a repeated deviation, or one that touches a statutory duty or changes the economics, is what justifies pausing the affected part.
After “Write the moderation SOP against a measurable response time”, compare the actual result with the baseline rather than with the impression of the team. If you will serve Chinese users directly, budget three to six months and complete filing before launch. If you reach those users only through a licensed domestic partner, put filing responsibility, content liability and audit rights into the contract. If the deployment is employee-only, write a short internal-use exemption memo and keep it on file. When the arrangement is extended to more products, customers or processes, keep the same success test and one complete record per batch. If later information changes, update only the affected fields.
One last discipline keeps the file usable next quarter: write the closing note as if a colleague who has never spoken to the supplier has to act on it. That note states what was verified, on which date, against which source, and what remains open — on “Guide: Filing a Generative-AI Service With CAC — Algorithm Filing, the Security-Assessment Pack and the Content-Moderation Evidence a Foreign-Invested Provider Must Hold” it also states which of the three actions was actually finished and which was only scheduled. Teams that skip the closing note re-litigate the same question every month, and each round costs more than the documentation would have. Summarises published filing requirements for planning purposes only; it is not a compliance opinion on your model, and CAC practice and documentation expectations vary by province and by service type.
Limits of the conclusion
Summarises published filing requirements for planning purposes only; it is not a compliance opinion on your model, and CAC practice and documentation expectations vary by province and by service type.
The limits are structural rather than cautious wording. Public sources describe rules and market conditions; they do not observe “Guide: Filing a Generative-AI Service With CAC — Algorithm Filing, the Security-Assessment Pack and the Content-Moderation Evidence a Foreign-Invested Provider Must Hold” inside a specific company. Where the analysis quotes a second-hand interpretation, the original release has to remain reachable, and a figure that cannot be traced back does not enter the decision table. Where the point depends on Covers consumer and enterprise services delivered to users in mainland China by app, mini-program, web portal or resold API. Purely internal tools, closed research environments and outbound-only services sit outside the filing duty, but the exemption has to be documented. Pre-check: who holds the ICP filing, whether the model is self-developed or licensed from an overseas vendor, and who owns the user data, the conclusion is only as current as the last check of those conditions.
