What is China’s AIGC Filing?
Generative AI products entering China face a regulatory requirement that does not have a direct equivalent in most overseas markets: the Generative Artificial Intelligence Service Filing, commonly called the AIGC Filing, Generative AI Filing, or Large Model Filing or 生成式人工智能服务备案 / 大模型备案 in Chinese.
For foreign companies, this is not simply a form submitted shortly before launch. It can affect the product’s model architecture, hosting arrangement, choice of Chinese operating entity, data flows, content moderation system, user agreements, and launch schedule.
Companies that build these requirements into the China product from the beginning have a much clearer route to market. Companies that address filing only after development is complete may discover that their overseas model or operating structure cannot support the required process.
This guide explains when the AIGC Filing applies, the difference between full model filing and application registration, and what foreign companies should prepare before providing a generative AI service in China.
What Is the China AIGC Filing?
China’s AIGC regulatory framework is based principally on the Interim Measures for the Management of Generative Artificial Intelligence Services, which took effect on 15 August 2023.
The Measures apply to services that use generative AI to provide text, images, audio, video, or other generated content to the public in Mainland China. The definition of a service provider includes companies offering generative capabilities through an API, not only companies operating a consumer-facing chatbot or app.
Under the framework, public-facing generative AI services with public-opinion attributes or social-mobilization capability must complete the applicable security assessment and algorithm procedures. In practice, the Cyberspace Administration of China, or CAC, implements these requirements through:
- Generative AI Service Filing for independently developed, fine-tuned, or independently deployed models; and
- Generative AI Application or Function Registration for applications that directly use a model that has already completed filing.
This means that any use of an AI Model must be registered and any new use of an independently deployed model must be filed.
As of 30 June 2026, the CAC reported that 988 generative AI services had completed filing and 598 applications or functions had completed registration. These figures show that filing and registration have become established parts of the China AI product-launch process, rather than exceptional requirements applying only to the largest technology companies.
Which Generative AI Services Need AIGC Filing?
A service is likely to fall within the framework when it:
- uses generative AI technology;
- generates text, images, audio, video, code, or similar content;
- is available to users in mainland China; and
- is provided to the public rather than used solely for internal research or operations.
Potentially covered products include:
- AI chatbots and virtual assistants;
- AI writing, translation, and summarization tools;
- image, audio, music, and video generators;
- coding assistants available to external users;
- AI search and question-answering products;
- customer-facing AI support functions;
- digital-human and voice-synthesis services;
- generative AI functions embedded in apps, websites, mini-programs, vehicles, or connected devices; and
- APIs that allow customers or end users to generate content.
An AI system used only by a company’s employees will generally fall outside the AIGC Filing regime because it is not being provided to the public. The same is usually true for internal research and development.
What Generative AI Services Have Already Received the AIGC Filing?
The CAC publishes and periodically updates its official list of filed generative AI services and registered applications. The list includes general-purpose language models, multimodal models, image and video generators, enterprise assistants, industry-specific models, and AI functions built into consumer devices.
Well-known examples include:
| Filed model or service name | Provider or associated product |
| 文心一言 | Baidu / ERNIE Bot |
| 智谱清言 (ChatGLM) | Zhipu AI |
| 云雀大模型 | ByteDance / the Doubao ecosystem |
| 百应 | Baichuan Intelligence |
| abab | MiniMax / the Hailuo AI ecosystem |
| 日日新 | SenseTime |
| 星火认知大模型 | iFlytek Spark |
| 通义千问大模型 | Alibaba / Qwen |
| 腾讯混元助手大模型 | Tencent Hunyuan |
| 华为云盘古 NLP 大模型 | Huawei Cloud Pangu |
| Moonshot | Moonshot AI / the Kimi ecosystem |
| WPS AI | Kingsoft Office |
| vivo 蓝心大模型 | vivo BlueLM |
| 安第斯大模型 | OPPO AndesGPT |
| DeepSeek | DeepSeek’s generative AI services |
| Apple智能 | Apple Intelligence for on-device services in China |
This table is representative rather than exhaustive. The CAC’s first consolidated list already contained 117 filed services, including models from Baidu, Alibaba, Tencent, Huawei, ByteDance, iFlytek, Zhipu AI, MiniMax, SenseTime, Moonshot AI, vivo, and OPPO. The list has expanded significantly since then. In July 2026, the CAC also announced seven newly filed on-device generative AI services, expressly naming Apple Intelligence (Apple智能).
Do You Need Full AIGC Filing or Application Registration?
The correct route depends primarily on who controls and operates the underlying model.
| Product structure | Likely requirement |
| The company has developed its own foundation model | Full Generative AI Service Filing |
| The company independently deploys an open-source model | Full Generative AI Service Filing |
| The company modifies or fine-tunes model weights | Full Generative AI Service Filing |
| The company operates a proprietary model in China | Full Generative AI Service Filing |
| The application directly calls a China-filed model through an API | Application or function registration |
| The application uses prompt templates over a filed model without changing its weights | Registration may be available |
| The application uses RAG with a filed model | Often registration, subject to the architecture and local CAC review |
| The application calls an overseas model that has not been filed in China | The simplified registration route will generally not be available |
| The AI function is restricted to genuine internal use | Generally outside AIGC Filing |
The CAC describes the registration route as applying to applications or functions that directly call the capabilities of an already-filed model through an API or another method.
Registration is lighter than full filing, but it is not automatic. The application provider remains responsible for its user interface, content controls, privacy practices, service agreements, complaint mechanisms, AI labels, and handling of unlawful user activity.
Fine-tuning is a particularly important dividing line. Prompt engineering or application-level configuration may remain compatible with registration. Changing model weights, merging models, independently deploying a modified model, or materially changing the model’s safety layer is much more likely to require full filing.
Is AIGC Filing the Same as Algorithm Filing?
Foreign companies frequently confuse the AIGC Filing with China’s Internet Information Service Algorithm Filing (互联网信息服务算法备案).
They are related, but they are not the same procedure.
| Procedure | What it reviews |
| Generative AI Service Filing | The model, training data, generated-content safety, security testing, and service controls |
| Generative AI Application/Function Registration | A downstream application using an already-filed model |
| Algorithm Filing | The generation or synthesis algorithm, operational risks, and algorithm-governance measures |
A public generative AI service may need both AIGC filing or registration and algorithm filing. This is often referred to as “double filing” or 双备案.
Neither procedure replaces other China internet requirements. Depending on the service, the provider may also need:
- an ICP Filing or Commercial ICP License;
- mobile app filing;
- public-security network filing;
- cybersecurity classified protection work;
- personal information and data-transfer compliance; and
- sector-specific approvals for areas such as news, healthcare, finance, education, publishing, or audiovisual content.
Completing an AIGC Filing does not authorize a company to operate an internet business that it is not otherwise licensed to provide.
What Do You Need to Prepare for Full AIGC Filing?
A full AIGC Filing requires both documentation and a working, testable compliance system. Although the exact process varies by province, the core submission normally covers the following areas.
1. Applicant and service information
The applicant must provide its corporate information, responsible personnel, service description, intended users, use cases, deployment arrangement, hosting providers, and any relevant internet or sector licences.
2. Model information
The filing describes the model’s architecture, version, functions, foundation model, training and fine-tuning methods, inference environment, computing resources, third-party dependencies, and model-update procedures.
3. Training-data compliance
The provider must be able to explain the sources, types, languages, and scale of its training data. It should retain evidence such as open-source licences, commercial dataset contracts, collection records, and user authorizations.
The review also examines:
- illegal and harmful information in training data;
- personal information and sensitive personal information;
- copyright and other intellectual-property risks;
- the quality, accuracy, and diversity of the data;
- data cleaning and filtering procedures; and
- data-labelling rules and quality control.
4. Model safety assessment
The provider must submit a detailed safety assessment supported by test results. The assessment typically covers unlawful and harmful outputs, discrimination, privacy and IP risks, hallucinations, reliability, prompt attacks, mandatory refusals, excessive refusals, and the effectiveness of content filters.
The current technical baseline is GB/T 45654-2025, Cybersecurity Technology—Basic Security Requirements for Generative AI Services.
The standard addresses areas including:
- traceability and filtering of training data;
- safety testing of model outputs;
- keyword and risk-classification libraries;
- refusal and non-refusal test sets;
- model backdoor and vulnerability testing;
- separation of training and inference environments;
- user controls over whether prompts are used for training;
- monitoring and incident response; and
- reassessment after material model updates.
5. User-facing compliance
The service must have China-compliant terms, a privacy policy, acceptable-use rules, complaint and reporting channels, minor-protection measures, and procedures for handling user requests concerning personal information.
The product should clearly state its intended users, use cases, limitations, and relevant model information.
6. A live test environment
Regulators may test the product directly. The applicant therefore needs stable test accounts, complete access to the relevant functions, and a technical contact who can respond during the review.
A common reason for delay is a mismatch between the written filing materials and the actual product. If the safety assessment describes a control that is absent or ineffective in the test environment, the application may require substantial remediation.
How Must AI-Generated Content Be Labelled in China?
Since 1 September 2025, generative AI providers have also been subject to the Measures for Labelling AI-Generated and Synthetic Content and the mandatory national standard GB 45438-2025.
The rules require two types of identification:
- Explicit labels that users can see or hear; and
- Implicit labels embedded in file metadata for identification and traceability.
Depending on the format, this may require visible notices around generated text, labels on images, notices in generated audio, labels in video opening frames, and metadata identifying the provider and content.
The labelling system must also work when content is downloaded, copied, or exported. App distribution platforms may request evidence that an AI service has implemented these requirements during app review.
How Do You Complete an AIGC Filing?
There is no single public national checklist that covers every province. The application normally begins with the CAC office responsible for the province in which the applicant entity is registered.
A typical project includes:
- assessing whether filing or registration applies;
- confirming the Chinese applicant and operating structure;
- consulting the provincial CAC and obtaining the current filing requirements;
- preparing the algorithm filing in parallel where appropriate;
- reviewing training-data provenance and legality;
- implementing content moderation, safety testing, AI labelling, and user controls;
- preparing the application forms and safety assessment;
- providing a test environment to the authorities;
- responding to questions and completing remediation; and
- receiving the filing number or application launch number and displaying it in the product.
There is no guaranteed national processing time. A full filing can take several months, particularly where the model requires repeated testing or remediation. Application registration using an already-filed model is generally more straightforward, but the duration still depends on the product and the relevant local authority.
Foreign companies should therefore treat AIGC compliance as an early product-development workstream rather than a final pre-launch formality.
What Challenges Do Foreign Companies Face?
The Interim Measures apply to services offered to users in Mainland China, including services supplied from overseas. However, an overseas entity can face challenges when applying due to entity regulations.
Common challenges include:
- identifying a suitable Chinese applicant entity;
- obtaining the necessary China internet licences;
- deploying the service through appropriate Chinese infrastructure;
- documenting overseas training data in sufficient detail;
- obtaining filing support from the foreign foundation-model owner;
- adapting content moderation to Chinese legal and regulatory requirements;
- controlling transfers of prompts, logs, and personal information outside China;
- implementing Chinese user agreements and complaint processes; and
- coordinating the AIGC, algorithm, ICP, app, and data-compliance workstreams.
For many foreign companies, the most practical structure is to operate the China application through a Chinese entity and use a foundation model that has already completed filing. The application can then pursue registration while retaining responsibility for the compliance of its own product layer.
By contrast, directly connecting a China-facing product to an unfiled overseas model can create a major obstacle. The application cannot ordinarily use the simplified registration route, while a full filing may require extensive technical evidence and cooperation from the overseas model provider.
What Happens After AIGC Filing or Registration?
Filing or registration is not the end of the compliance process. Providers must continue to:
- display the model name and filing number or application launch number;
- update content filters and safety-test libraries;
- monitor generated content and abusive use;
- stop and remove unlawful content where required;
- restrict or suspend users who repeatedly misuse the service;
- protect prompts, logs, and personal information;
- maintain complaint and reporting channels;
- keep explicit and metadata AI labels operational;
- report serious incidents to the relevant authorities;
- reassess material model updates; and
- complete change procedures when filing information changes.
In 2026, the CAC made failure to complete required model filing or registration one of the targets of its nationwide campaign addressing AI application irregularities. Other enforcement priorities include unsafe training data, inadequate content filtering, AI data poisoning, deficient labelling, and misuse of AI-generated content.
Possible consequences include regulatory interviews, rectification orders, warnings, suspension of an AI function, app or website takedown, and penalties under China’s cybersecurity, data, personal information, and content laws.
How Can AppInChina Help?
Launching a generative AI service in China requires coordination across product design, cloud infrastructure, internet licensing, model compliance, data protection, and regulatory filing.
AppInChina helps foreign companies assess and implement the China-specific route to market, including:
- determining whether full AIGC Filing or application registration applies;
- assessing whether the proposed foundation model can support a China launch;
- establishing the required Chinese operating and hosting structure;
- coordinating ICP, app, algorithm, and generative AI compliance requirements;
- supporting preparation of the filing and safety-assessment materials;
- helping align the product with China’s content moderation and AI-labelling standards; and
- managing communication and implementation across the relevant China service providers and regulatory workstreams.
If your company plans to launch an AI-powered app, website, API, connected device, or digital service in China, contact us for a free initial compliance assessment.