In mainland China, a generative AI service aimed at the public cannot simply be switched on. Two separate administrative steps sit between a working product and a lawful public launch, and they are governed by two different instruments that are routinely conflated.
The Interim Measures for the Management of Generative AI Services (生成式人工智能服务管理暂行办法) were issued on 13 July 2023 by the Cyberspace Administration of China together with six other central departments, and took effect on 15 August 2023. The official text is published by the CAC: the Interim Measures as promulgated. The word “interim” (暂行) in the title is doing real work: this is expressly a provisional instrument, and the surrounding rules have already changed around it, notably with the 2025 content-labelling measures.
This page describes the published text of the Measures. It is not legal advice, and Chinese regulatory practice is substantially shaped by how the CAC and its provincial offices apply the text in a given review cycle, which no summary can convey. Take Chinese advice on your own service before relying on any of it.
Article 2 sets the scope: the Measures apply to the use of generative AI technology to provide services generating text, pictures, audio, video and similar content to the public within mainland China. Two exclusions follow directly from that wording and both matter commercially.
The filing duty itself is narrower than the Measures as a whole. Article 17 requires a security assessment and algorithm filing only from providers of generative AI services with public opinion attributes or social mobilisation capability (舆论属性或者社会动员能力). That phrase is a term of art carried over from earlier Chinese internet regulation and it is broad in practice: a service that lets members of the public generate and see content, or that can be used to organise, is generally treated as within it. A narrow business-to-business tool with no public-facing content surface may not be, but that determination is a judgement call and not a self-evident one.
The order is not optional, and the commonest planning error is budgeting for one step where there are two with a dependency between them.
Article 17 is a precondition, not a formality to be completed in parallel with a soft launch. The practical effect visible from outside China is that the CAC periodically publishes lists of generative AI services that have completed filing, and a domestic consumer launch by a name absent from those lists is unusual.
The filing is a description of the algorithm and the accountability around it rather than a technical audit. It asks who the provider is, what form the service takes, what domain it applies to, what type of algorithm it is, and—the substantive part—an algorithm self-assessment report, plus the material to be publicised.
The obligations the assessment has to demonstrate compliance with are elsewhere in the Measures, and these are the ones with ongoing engineering consequences:
The first mistake is assuming the algorithm filing satisfies Article 17 on its own. It does not; the security assessment is a separate step under a separate instrument with a separate submission, and completing the filing while skipping the assessment leaves the launch precondition unmet.
The second is assuming the Measures are the whole of the applicable law. They sit on top of the Cybersecurity Law, the Data Security Law and the Personal Information Protection Law, and a generative AI service handling Chinese personal information faces PIPL obligations including the cross-border transfer regime, which is frequently the harder problem.
The third is architectural. A service that reaches mainland users through an endpoint outside China is not automatically outside the Measures, and a service that has been filed is filed for the algorithm described in the filing—swapping the underlying model for a different one is the kind of change the filing regime expects to be told about.
If one product serves several regions from one codebase, the filing question is really a routing question: which upstream endpoint does a given user’s request actually reach, and is that endpoint the one covered by whatever registration exists. A gateway that lets you pin routes per region and keeps a per-request record of which upstream served it makes that answerable from logs rather than from architecture diagrams; Multigrid records the resolved upstream on every request for exactly this class of question.