The Complete Guide to China’s AIGC Registration

Foreign companies do not always need to complete a full large-model filing to launch a generative AI product in China. If an app, website, SaaS platform, connected device, or other digital service directly uses a model that has already completed China’s Generative AI Service Filing, the product likely only has to complete the AIGC Registration, known in Chinese as the 生成式人工智能应用或功能登记

This guide explains when AIGC Registration is necessary, when full AIGC Filing is still required, and how foreign companies can structure a China-facing AI application around an already-filed model.

What Is AIGC Registration in China?

AIGC Registration is the compliant route used for a generative AI application or function that directly calls the capabilities of a model that has already completed filing with the Cyberspace Administration of China, or CAC.

The CAC describes this category as applications or functions that directly use the capabilities of a filed model through an API interface or another method. Unlike a full model filing, the registration is handled primarily by the applicant’s local or provincial cyberspace authority.

Following completion, the application receives an online launch number (上线编号). The application must disclose the relevant filed or registered service information in a prominent location or on its product-details page.As of 30 June 2026, 598 generative AI applications or functions have completed registration in China, compared with 988 generative AI services that had completed full filing.

Which Significant AIGC Applications Have Already Been Registered?

The CAC’s official list for May and June 2026 illustrates how broadly the registration route is now being used. The entries include consumer platforms, financial institutions, manufacturers, public-service bodies, publishers, and hospitals.

Selected notable registrations include:

Registered application or function	Registration entity	Why it is notable
腾讯音乐歌声唱作大模型 (Tencent Music singing and songwriting model)	Tencent Music Entertainment Technology (Shenzhen) Co., Ltd.	Music creation and consumer entertainment
格力智能大模型 (Gree intelligent model)	Gree Electric Appliances, Inc. of Zhuhai	AI from a major household-appliance manufacturer
南方基金理财助手大模型 (Southern Asset Management financial assistant)	Southern Asset Management Co., Ltd.	Regulated financial-services use
12345智能体 (12345 intelligent agent)	Beijing Citizen Hotline Service Center	Municipal public-service and citizen-support use
吃鲸AI	Beijing iQIYI Science & Technology Co., Ltd.	Consumer media and entertainment
小泰同学智能助手 (Xiao Tai intelligent assistant)	Taikang Insurance Group Inc.	Insurance-sector application
滴滴平台智能客服 (Didi platform intelligent customer service)	Didi Chuxing (Beijing) Network Platform Technology Co., Ltd.	AI customer service on a major mobility platform
陇上小郎中	Gansu Provincial Hospital of Traditional Chinese Medicine	Hospital and healthcare use
新华语典	Xinhua News Agency	News, publishing, and language-reference use
网易有道词典 (NetEase Youdao Dictionary)	Beijing NetEase Youdao Computer System Co., Ltd.	A widely used dictionary and language-learning product
舒压伴·PressGuard	Jiangsu Province Hospital	Hospital and wellbeing application

What Are the Key Points About AIGC Registration?

• Registration is intended for an application that directly uses an already-filed generative AI model.
• The underlying model’s exact filing status must be verified before the application relies on it.
• Registration normally avoids the full review of the foundation model’s original training process and training corpus.
• The application provider still needs its own safety, privacy, content-moderation, user-protection, and AI-labelling measures.
• Registration is handled principally through the applicant’s local cyberspace authority and results in an 上线编号.
• The application may still require algorithm filing, ICP or app filing, Chinese hosting, cybersecurity work, and sector-specific approvals.
• Modifying model weights, independently deploying a model, or substantially changing the model may move the product from registration to full filing.
• Foreign companies should confirm the regulatory route before finalizing their model provider, China entity, hosting, and data architecture.

Who Needs AIGC Registration?

Registration is potentially relevant when a company provides a generative AI application or function to the public in mainland China but does not independently operate a new or modified foundation model.

Typical examples include:

• an AI writing assistant that calls a filed Chinese language model;
• a customer-service chatbot built on a filed model API;
• an image or video editing app that uses a filed generative model;
• an AI translation or summarization function in a SaaS product;
• an AI search or question-answering feature;
• a productivity app with document-analysis and content-generation functions;
• an AI assistant embedded in a vehicle, mobile device, or connected product;
• a mini-program that generates content using a filed third-party model; and
• an industry application that uses a filed model without independently training or operating a new model.

The relevant question is not whether the AI feature is the product’s main function. A generative AI function embedded in a larger app can still require registration if it is made available to the public and falls within China’s generative AI regulatory framework.

Services used only for genuine internal research or by a company’s own employees will generally fall outside the public-facing AIGC registration system. Closed B2B services and limited customer deployments require a case-by-case assessment because the meaning of “provided to the public” can depend on the product structure and local regulatory interpretation.

When Can an Application Use Registration Instead of Full Filing?

An application is most likely to qualify for registration when all of the following conditions are satisfied:

1. The underlying model has already completed China’s Generative AI Service Filing.
2. The application directly accesses that filed model through an authorized API, SDK, cloud service, or another accepted technical arrangement.
3. The application provider does not independently train, fine-tune, merge, or materially alter the model.
4. The model provider can supply the filing information and cooperation needed for the application’s registration.
5. The application provider implements its own controls for the product’s use cases and users.

Prompt templates, workflow design, application-level orchestration, and an independent user interface do not necessarily require full model filing. They may remain compatible with registration if the underlying filed model is unchanged.

Retrieval-augmented generation, or RAG, requires closer analysis. Using a knowledge base to supply context to an unchanged filed model may still fit the registration route. However, the result depends on how the knowledge base, retrieval system, safety controls, and generation process change the application’s outputs. The applicant should confirm this structure with its local CAC before relying on registration.

When Is AIGC Registration Not Available?

Registration will generally not be the appropriate route when the provider is independently operating a new or modified model.

Full AIGC Filing is more likely to be required where the company:

• develops its own foundation model;
• deploys an open-source model independently for public use;
• changes or fine-tunes model weights;
• uses LoRA or another model-training method to create a distinct model;
• distils, merges, or materially modifies models;
• independently controls the model’s core training or alignment process;
• uses an overseas model that has not completed filing in China; or
• cannot demonstrate that the precise underlying model is covered by an existing filing.

Changing only the product interface does not normally create a new model. Changing the model itself can.

An application that directly calls an unfiled overseas model cannot ordinarily use the simplified registration route merely because the application is operated by a Chinese entity. The underlying filed-model requirement remains the central eligibility condition.

How Does AIGC Registration Differ from Full AIGC Filing?

Requirement	AIGC Registration	Full AIGC Filing
Typical applicant	Application provider using a filed model	Provider operating its own, modified, or independently deployed model
Underlying model	Must already have a valid China filing	Reviewed as part of the filing
Model training review	Generally limited because the foundation model is already filed	Detailed review of training data, model development, and safety alignment
Training-data evidence	Normally focused on application data and knowledge sources	Extensive evidence covering training-data sources, legality, quality, and labelling
Main review focus	Application functions, use cases, data flows, output controls, user protection, and model relationship	Model architecture, training corpus, model safety, generated-content testing, and service controls
Review level	Principally the local or provincial CAC	Provincial review followed by national-level review
Result	Online launch number, or 上线编号	Filing number, or 备案号
Relative complexity	Lighter, but still substantive	Significantly more complex and technical

Registration is therefore better understood as a different compliance route rather than a simple exemption from filing.

For a broader explanation of the full model-filing regime, see AppInChina’s guide to China’s AIGC Filing.

How Can You Confirm That a Model Has Already Been Filed?

The CAC periodically publishes an official consolidated list of filed generative AI services and registered applications.

Before selecting a model for a China application, the product provider should verify:

• the exact filed model or service name;
• the filing entity;
• the filing number;
• the province or jurisdiction;
• whether the filing covers the intended modality and service arrangement;
• whether the API or model version being purchased is the filed service; and
• whether the filing remains current following model updates.

A familiar commercial name is not enough. The official filing may use a technical model name that differs from the consumer-facing brand. One provider may also operate several models, endpoints, versions, or modalities under separate filings.

The application provider should obtain written confirmation from the model provider and include appropriate cooperation obligations in the commercial agreement. The contract should address filing information, regulator queries, changes to the model, safety incidents, service continuity, data handling, and notification if the underlying filing or model architecture changes.

What Documents Are Required for AIGC Registration?

China has not published one uniform national registration checklist for every province. The exact documents, submission format, testing process, and terminology are controlled in practice by the applicant’s local CAC.

A typical registration package may include:

• the local generative AI application or function registration form;
• the applicant’s business licence and responsible-person information;
• a detailed description of the product, functions, intended users, and use cases;
• the underlying model’s name, provider, filing number, and proof of filing;
• the API, SDK, cloud-service, or model-service agreement;
• a technical architecture and data-flow description;
• an explanation of prompts, RAG, knowledge bases, plug-ins, agents, and other application-layer processing;
• the user agreement and privacy policy;
• prohibited-use and user-management rules;
• content-safety and illegal-content interception measures;
• keyword, classification, and output-review controls;
• safety evaluation questions and test results;
• complaint, reporting, and incident-response procedures;
• minor-protection measures where relevant;
• AI-generated content labelling materials;
• algorithm-filing information or supporting materials; and
• stable test accounts or an accessible test interface.

Because local requirements change, applicants should obtain the current form and evidence list directly from the relevant CAC office before preparing the final submission.

What Product Controls Must Be Ready Before Registration?

Using a filed foundation model does not transfer all compliance responsibility to the model provider. The downstream application controls how the model is presented, what data is supplied to it, which users can access it, and how the generated content is used.

The application should therefore be able to:

• detect and block prohibited or harmful user inputs;
• review model outputs before they are displayed or distributed;
• restrict users who repeatedly attempt to generate unlawful content;
• define appropriate uses, users, and limitations;
• protect prompts, uploaded files, logs, and other personal information;
• avoid collecting personal information that is not necessary for the service;
• process requests to access, correct, or delete personal information;
• provide a clear complaint and reporting channel;
• respond to safety incidents and regulator requests;
• monitor the quality and safety of the service over time; and
• maintain an alternative plan if the model provider changes or withdraws the relevant service.

The controls described in the registration documents must exist in the live test environment. Generic policies that do not match the actual product can lead to questions, remediation, or rejection.

How Must Registered Applications Label AI-Generated Content?

Registered applications must comply with China’s Measures for Labelling AI-Generated and Synthetic Content and the mandatory national standard GB 45438-2025.

Depending on the service, the application may need:

• visible text or interface notices for generated text;
• visible labels on generated images;
• audio or interface notices for generated audio;
• labels in video opening frames and around the video player;
• labels for virtual scenes; and
• machine-readable metadata identifying content as AI-generated.

Labels must continue to work when content is downloaded, copied, or exported. The application’s user agreement should explain the labelling method and the user’s responsibilities when publishing generated content.

The application cannot assume that the foundation-model provider’s labelling controls will automatically satisfy the product’s obligations. The downstream interface, export function, file processing, and content-distribution workflow must also be assessed.

How Do You Complete AIGC Registration?

A typical registration project follows these stages:

Stage 1: Assess the Product Architecture

Confirm that the service is public-facing, uses generative AI, and directly calls a model that has already completed filing. Identify any fine-tuning, RAG, agent, plug-in, or application-layer functions that could affect the route.

Stage 2: Confirm the China Applicant

Determine which entity will operate the China product, contract with the model provider, control user data, maintain the service, and communicate with the local CAC.

Stage 3: Consult the Local CAC

Contact the cyberspace authority responsible for the applicant’s jurisdiction. Confirm that registration is available for the proposed architecture and obtain the current form, document list, and testing instructions.

Stage 4: Secure Model-Provider Support

Obtain the model’s exact filing information, service agreement, technical documentation, data-handling details, and a commitment to assist with regulatory questions and future changes.

Stage 5: Prepare the Product and Documents

Complete the registration form, technical description, user-facing policies, content controls, safety testing, AI labels, complaint process, and test environment.

Stage 6: Submit for Local Review

Provide the registration materials and test access to the local authority. The authority may review the documents, test the service, and request explanations or remediation.

Stage 7: Receive and Display the Online Launch Number

Once registration is completed, the application receives an 上线编号. The product should prominently disclose the registered service information, relevant model name, and filing or launch number as required.

The exact sequence varies by province. Some authorities may request preliminary product information or testing before accepting the complete package.

Does AIGC Registration Replace Algorithm Filing or ICP Filing?

No. AIGC Registration addresses the application’s use of a filed generative AI model. It does not replace other China internet approvals.

A registered application may also require:

Requirement	Why it may apply
Internet Information Service Algorithm Filing	The product provides generation or synthesis functions with public-opinion attributes or social-mobilization capability
ICP Filing or Commercial ICP License	The website, SaaS platform, or online service is hosted or commercially operated in China
Mobile App Filing	The generative AI function is provided through a mobile app distributed in China
Public Security Bureau Filing	The China-hosted website or service falls within the relevant public-security registration requirements
Cybersecurity classified protection	The China information system requires classified cybersecurity protection measures
Personal information and data-transfer compliance	The app processes Chinese users’ prompts, files, account information, identifiers, or logs
Sector approval	The service operates in news, publishing, healthcare, finance, education, audiovisual content, mapping, or another regulated sector

The CAC’s algorithm filing system is separate from the local AIGC registration process. In practice, app stores and platform partners may ask for the relevant filing or registration information before allowing a generative AI product to launch.

How Long Does AIGC Registration Take and What Does It Cost?

There is no uniform national statutory processing period for AIGC Registration. Timing depends on:

• the applicant’s province;
• the completeness of the documentation;
• the product’s use cases and risk level;
• the number of models and AI functions involved;
• whether the model provider supplies the necessary evidence promptly;
• the application’s safety-test results; and
• the number of remediation rounds.

Registration is normally less complex than full AIGC Filing because the underlying model has already been reviewed. Companies should nevertheless allow several weeks to several months for route confirmation, document preparation, product testing, authority review, and remediation. Registration should be planned as a pre-launch workstream rather than left until app-store submission.

The government procedure itself is not the only cost. A project may require Chinese cloud services, model API fees, product localization, legal and technical documentation, safety testing, content moderation, algorithm filing, privacy work, and local compliance support.

What Happens After AIGC Registration?

Registration creates ongoing responsibilities. The application provider should continue to:

• display the required model and registration information;
• maintain its relationship with the filed-model provider;
• monitor model and API changes;
• update safety filters and testing materials;
• keep AI-generated content labels operational;
• handle unlawful content and user misuse;
• preserve relevant incident and remediation records;
• protect user data and respond to personal-information requests;
• maintain complaint and reporting channels;
• cooperate with regulator testing and inspections; and
• assess whether material product or model changes require an update, new registration, or full filing.

Registration does not mean that every future version of the application is automatically covered. Adding a new model, modality, use case, knowledge source, agent capability, or high-risk function may change the original assessment.

The CAC’s 2026 nationwide campaign addressing AI application irregularities specifically identifies failure to complete required model filing or registration as an enforcement target. Providers should therefore keep the registered product, live technical controls, and public disclosures aligned.

What Common Mistakes Delay AIGC Registration?

Common problems include:

• assuming that the model provider’s filing automatically covers the application;
• checking the commercial model name but not the exact official filing entry;
• using a model version or endpoint that is not covered by the evidence supplied;
• calling an unfiled overseas model;
• describing the product as direct API use when the company has actually fine-tuned or independently deployed the model;
• failing to disclose RAG, agents, plug-ins, knowledge bases, or secondary models;
• starting registration after committing to a China launch date;
• relying on the foundation model’s filters without application-level controls;
• using overseas privacy terms that do not match the China product;
• failing to implement explicit and metadata AI labels;
• providing incomplete or expiring test accounts;
• submitting documents that do not match the live product; and
• overlooking algorithm, ICP, app, cybersecurity, or sector-specific requirements.

The most effective way to avoid these issues is to decide the registration architecture before finalizing the model contract and China technical deployment.

How Can AppInChina Help?

AppInChina helps foreign companies build and implement a compliant route for AI-powered apps, SaaS platforms, websites, APIs, connected devices, and other digital services in China.

Our support can include:

• assessing whether registration, full AIGC Filing, or neither procedure applies;
• identifying a suitable already-filed model for the China application;
• confirming the China applicant, hosting, and operating structure;
• coordinating with the model provider on filing evidence and technical support;
• preparing the AIGC registration materials and product disclosures;
• aligning the product with China’s content-safety and AI-labelling requirements;
• coordinating algorithm filing, ICP, mobile app, and related compliance work; and
• supporting ongoing changes after the application receives its online launch number.

If your company plans to launch a generative AI function in China using a third-party model, contact us for a free compliance assessment to see what you need to smoothly enter China’s digital market.