What the algorithm and generative-AI rules actually say
| Fact | Primary source |
|---|---|
| Article 24: the filing duty attaches to providers with public-opinion attributes or social-mobilisation capacity — not to every company using AI in China — and is due within ten working days of the day the service begins. | Provisions on the Administration of Algorithmic Recommendation of Internet Information Services, Article 24 |
| Article 2: “algorithmic recommendation technology” covers five categories — generative-synthetic, personalised-push, ranking-and-selection, retrieval-and-filtering, and scheduling-and-decision — so a search ranking or a product feed is in scope, not only generative models. | Algorithmic Recommendation Provisions, Article 2 |
| Article 24: changes to filed information must be reported within ten working days; termination requires deregistration within twenty working days. | Algorithmic Recommendation Provisions, Article 24 |
| Article 25: where materials are complete, the cyberspace authority completes the filing within thirty working days, issues a filing number and publishes it; incomplete materials are refused within the same window. | Algorithmic Recommendation Provisions, Article 25 |
| Article 26: the filing number must be shown in a prominent position on the service, with a link to the published information. | Algorithmic Recommendation Provisions, Article 26 |
| Article 31: breach draws a warning and an order to rectify; on refusal or in serious cases, an order to suspend information updates plus a fine of RMB 10,000–100,000. Article 33: a filing obtained by concealment is revoked. | Algorithmic Recommendation Provisions, Articles 31 and 33 |
| Generative AI, Article 17: providers with public-opinion attributes or social-mobilisation capacity must run a security assessment and complete algorithm filing under the 2022 provisions — there is no separate generative-AI filing. | Interim Measures for the Administration of Generative AI Services, Article 17 |
| Generative AI, Article 2: the measures apply to providing generated text, images, audio or video to the public inside China; R&D not offered to the public inside China is expressly outside them. | Generative AI Interim Measures, Article 2 |
| Generative AI, Article 20: where a service provided from outside China into China does not comply, the State cyberspace authority shall notify relevant bodies to take technical measures to deal with it. | Generative AI Interim Measures, Article 20 |
Sources verified by the 21YunBox China engineering team on 2026-08-28.
What is China AI Algorithm Filing?
Algorithm filing (算法备案) is a registration with the Cyberspace Administration of China for services that use recommendation algorithms. It is a filing, not a licence: there is no approval to win, but there is a deadline, a public number you must display, and a penalty for missing it.
Most English explanations of it are paraphrases. The instrument is short, and the articles that decide whether it applies to you are worth reading in the original.
Instruments: 《互联网信息服务算法推荐管理规定》 — Provisions on the Administration of Algorithmic Recommendation of Internet Information Services, issued jointly by the CAC, MIIT, the Ministry of Public Security and SAMR, in force since 1 March 2022; and 《生成式人工智能服务管理暂行办法》 — Interim Measures for the Administration of Generative AI Services, in force since 15 August 2023.
What counts as a recommendation algorithm is broader than “AI”
第二条 在中华人民共和国境内应用算法推荐技术提供互联网信息服务（以下简称算法推荐服务），适用本规定。……
前款所称应用算法推荐技术，是指利用生成合成类、个性化推送类、排序精选类、检索过滤类、调度决策类等算法技术向用户提供信息。
Article 2. These Provisions apply to the use of algorithmic recommendation technology to provide internet information services within the territory of the People’s Republic of China. … “Using algorithmic recommendation technology” means using generative-synthetic, personalised-push, ranking-and-selection, retrieval-and-filtering, or scheduling-and-decision algorithm technologies to provide information to users.
In practice: five categories, and only the first is what a Western product team would call “AI”. A personalised product feed is 个性化推送类. A search results ranking is 排序精选类. A content filter is 检索过滤类. Teams often check whether they are “doing AI” when the question the regulation asks is much wider.
Who Needs China AI Algorithm Filing?
Not everyone using those algorithms. The obligation attaches to a specific qualifier, and it is the single most important phrase on this page:
第二十四条 具有舆论属性或者社会动员能力的算法推荐服务提供者应当在提供服务之日起十个工作日内通过互联网信息服务算法备案系统填报服务提供者的名称、服务形式、应用领域、算法类型、算法自评估报告、拟公示内容等信息，履行备案手续。
算法推荐服务提供者的备案信息发生变更的，应当在变更之日起十个工作日内办理变更手续。
算法推荐服务提供者终止服务的，应当在终止服务之日起二十个工作日内办理注销备案手续，并作出妥善安排。
Article 24. An algorithmic recommendation service provider with public-opinion attributes or social-mobilisation capacity shall, within ten working days of the date it begins providing the service, complete filing formalities through the Internet Information Service Algorithm Filing System, submitting the provider’s name, service format, application field, algorithm type, algorithm self-assessment report, and the content proposed for public disclosure. Where filed information changes, change formalities shall be completed within ten working days of the change. Where the service is terminated, deregistration shall be completed within twenty working days of termination, with appropriate arrangements made.
In practice: the trigger is 具有舆论属性或者社会动员能力 — public-opinion attributes or social-mobilisation capacity. In practice that means services carrying user-generated content, public comment, or channels able to organise people at scale. A recommendation engine inside a closed B2B application is a different case from a consumer app with a public feed, and the regulation does not treat them the same. Anyone telling you every company deploying AI in China must file is describing a rule that is not written here.
The clock is ten working days from the day you start serving, not from launch approval. Filing is something you do after going live, which is why it is frequently discovered late.
The authority’s own clock is thirty working days
第二十五条 国家和省、自治区、直辖市网信部门收到备案人提交的备案材料后，材料齐全的，应当在三十个工作日内予以备案，发放备案编号并进行公示；材料不齐全的，不予备案，并应当在三十个工作日内通知备案人并说明理由。
Article 25. After receiving the materials submitted by the filer, the national or provincial cyberspace authority shall, where the materials are complete, complete the filing within thirty working days, issue a filing number and publish it; where materials are incomplete, it shall not file, and shall notify the filer with reasons within thirty working days.
In practice: the same structure as the ICP filing — a statutory window measured from a complete submission, so incomplete materials restart it rather than shorten it.
And the number goes on the page
第二十六条 完成备案的算法推荐服务提供者应当在其对外提供服务的网站、应用程序等的显著位置标明其备案编号并提供公示信息链接。
Article 26. A provider that has completed filing shall indicate its filing number in a prominent position on the website, application or other service it provides externally, and provide a link to the published information.
In practice: this is why filed Chinese AI services carry a 网信算备 number in the footer — the same pattern as the ICP number, from a different regulator.
What happens if you skip it
第三十一条 算法推荐服务提供者违反本规定……第二十四条、第二十六条规定……由网信部门和电信、公安、市场监管等有关部门依据职责给予警告、通报批评，责令限期改正；拒不改正或者情节严重的，责令暂停信息更新，并处一万元以上十万元以下罚款。
Article 31. Where a provider breaches Article 24 or Article 26 … the cyberspace, telecommunications, public security and market regulation authorities shall, within their respective remits, give a warning or public criticism and order rectification within a time limit; where rectification is refused or the circumstances are serious, they shall order suspension of information updates and impose a fine of between RMB 10,000 and RMB 100,000.
In practice: 责令暂停信息更新 — ordered suspension of information updates — is the sanction to plan around, not the fine. A recommendation service that cannot update is a product that has stopped working while still being online. Article 33 adds that a filing obtained by concealment or false materials is revoked outright.
If your service is generative AI
The generative AI measures do not create a separate filing. They point back at this one:
第十七条 提供具有舆论属性或者社会动员能力的生成式人工智能服务的，应当按照国家有关规定开展安全评估，并按照《互联网信息服务算法推荐管理规定》履行算法备案和变更、注销备案手续。
Article 17. A provider of generative AI services with public-opinion attributes or social-mobilisation capacity shall carry out a security assessment in accordance with relevant State provisions, and complete algorithm filing, change and deregistration formalities in accordance with the Provisions on the Administration of Algorithmic Recommendation of Internet Information Services.
In practice: same trigger phrase, plus a security assessment on top. And the scope rule is narrower than people assume — Article 2 of the same measures excludes research and development that is not offered to the public inside China, so an internal model that never faces Chinese users is outside it.
The article that makes this a delivery question
第二十条 对来源于中华人民共和国境外向境内提供生成式人工智能服务不符合法律、行政法规和本办法规定的，国家网信部门应当通知有关机构采取技术措施和其他必要措施予以处置。
Article 20. Where a generative AI service provided into the territory from outside the People’s Republic of China does not comply with laws, administrative regulations or these Measures, the State cyberspace authority shall notify the relevant bodies to take technical measures and other necessary measures to deal with it.
In practice: this is the second gate written down. Serving from offshore does not place a generative AI product outside the regime; it places it inside a regime whose stated remedy is technical measures. Reachability and permission are the same decision here, and we have measured what each delivery arrangement actually buys for the first half of it.
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Primary sources: 《互联网信息服务算法推荐管理规定》, full text published by the State Council: gov.cn. 《生成式人工智能服务管理暂行办法》, full text published by the Cyberspace Administration of China: cac.gov.cn. Filed algorithms are publicly listed by the CAC.
Translations above are ours and are provided for orientation only. Where the English and the Chinese differ, the Chinese governs. This page is not legal advice.
