Before We Begin, The Original Content of Overheaven Must Not Be Plagiarized or Reproduced. If I Find Out, I Will Pursue It to the End! Please Have Some Decorum, Competitors, Don’t Make Me Expose You.
This article records my journey over the past year in handling algorithm filing-related business, accompanying and observing the growth and progress alongside the requirements of algorithm filing policies. What insights can everyone gain from this documented history of algorithm filing, and what trends can we infer about the future development of AI in our country?
In April 2023, ChatGPT sparked a generative AI frenzy in the country, followed closely by Baidu’s Wenxin Yiyan, leading to a surge of generative AI product applications in the market.
In June 2023, due to the public opinion attributes of content generated by generative AI, the Cyberspace Administration of China (CAC) urgently issued the “Interim Measures for the Management of Generative AI Services” and the “Regulations on the Management of Deep Synthesis of Internet Information Services”, requiring all entities providing generative AI services to the public within the country to file their algorithms and mandating that product distribution channels share the responsibility for review. Algorithm filing has become a stringent management condition for the legal and compliant launch and operation of AIGC products. Responsible persons of products that are not filed will be summoned for discussions, and the products must be taken offline for at least two months for filing.
In April 2024, ICP filing (not ICP license, only ICP domain filing) became a mandatory prerequisite for algorithm filing. This marks a shift in China’s AI algorithm filing review work from “incremental” to “quality improvement”. The threshold requirements for algorithm filing have begun to rise.
In August 2024, the CAC tightened the review of application materials for multimodal generative AI products, requiring that each algorithm involved in the documentation be written separately by modality.
In September 2024, the CAC issued a notice soliciting opinions on the draft mandatory national standard “Cybersecurity Technology – Identification Methods for AI-Generated Synthetic Content”, which will enforce standardized management of identification functions for AIGC products. New regulations are about to be released, and review policies will further tighten.
In October 2024, the CAC further required entities using third-party content review services to provide not only screenshots of the third-party content review backend management page but also contracts for the use of third-party content review services, further increasing the normative requirements for algorithm filing reviews.
In December 2024, the Central Cyberspace Affairs Commission began random checks and verifications of the filing materials about to be issued, with the verification conducted via phone calls. The local CAC responsible for the reporting entity will contact them by phone to inquire and verify whether the algorithms, products, and company information match the submitted materials.
In December 2024, the CAC only issued numbers for algorithms that passed the review from mid-October to early November (411 in this batch, 509 in the eighth batch, 487 in the seventh batch, and 492 in the sixth batch). Algorithms submitted for review after early November have not been issued and remain under review, needing to wait for subsequent batches for sequential issuance. The Chinese AI market is booming, with an explosive growth in AI applications, but the CAC is understaffed, under too much pressure, and materials are piling up, leading to slow review progress; based on the backlog situation at the CAC, the future review efficiency may not be optimistic, and the efficiency and strictness of algorithm filing reviews may align more closely with game license issuance.
In February 2025, in some regions, the form of material verification has shifted to offline verification, where some local CACs require filing entities to bring both electronic and paper versions of all filing materials to the CAC for face-to-face verification and questioning.
A Sincere Reminder from Overheaven: Algorithm Filing
As long as you want to do this
Act quickly to investigate and implement!
Algorithm filing will only become stricter.
For small and medium-sized enterprises, algorithm filing will only become more challenging!
Getting products through algorithm filing and legally and compliantly launching and promoting them boldly to seize market share is the priority!
The competition in the AI market is fierce, and algorithm filing provides the foundation!
Otherwise, you will need to guard against: inspections from the CAC, critical users, and competing businesses. If reported, products will be taken offline for at least two months, and all your hard work will go to waste!
I believe no one wants their creative and painstakingly developed products to remain in the shadows and not be able to compete openly with others on quality, operation, and planning.