China AI Regulation
// Binding Verticals + Non-Binding Framework 3.0 - Filed, Assessed, Labelled, Referenced
China never waited for an omnibus AI law. Binding vertical regulations stack per technology: algorithms must be filed with the CAC, generative services must pass security assessment before launch, and every piece of AI-generated content now carries visible and embedded labels. Released September 14, 2026 with no effective date, AI Safety Governance Framework 3.0 is a non-binding preview: Annex 2 reference controls for agent identity and permissions, reasoning and planning, tool invocation and execution, and memory storage, plus a Section 4.3 sandbox direction to be written and Annex 1 grading carried over from 2.0.
Key Highlights
Which binding rules already bite, plus the non-binding Framework 3.0 agent layer that previews what may bind next.
- 01
China already operates the world’s most prescriptive AI rulebook. Instead of one omnibus act, binding vertical regulations stack per technology: recommendation algorithms, deep synthesis, generative AI, and content labelling.
- 02
The Algorithmic Recommendation Provisions (effective March 2022) require filing significant algorithms with the Cyberspace Administration of China, publishing algorithm summaries, honoring opt-outs from personalization, and protecting gig-worker scheduling rights.
- 03
The Deep Synthesis Provisions (effective January 2023) mandate consent for manipulating biometric features and conspicuous labels on AI-generated media.
- 04
The Interim Measures for Generative AI Services (effective August 2023) require a security assessment plus algorithm filing before any public-facing generative service launches, along with lawful training data, IP respect, content controls, and minors protection.
- 05
Content labelling went national on September 1, 2025: Measures for Labeling AI-Generated Content force explicit visible marks and implicit metadata labels across generation, upload, and dissemination platforms, backed by the GB 45438-2025 standard.
- 06
Security assessments follow the TC260 generative AI security requirements, including corpus contamination limits and multi-thousand-question red-team test sets, making evaluation infrastructure a launch dependency rather than an afterthought.
- 07
Network Data Security Regulations (effective January 2025) extend training-data compliance duties, and a horizontal Artificial Intelligence Law sits in the legislative pipeline to consolidate the stack.
- 08
Enforcement is real: the CAC suspends and removes non-compliant apps, so filing status and labelling fidelity are availability issues, not paperwork.
- 09
AI Safety Governance Framework 3.0 (released September 14, 2026 per CAC notice, cover dated September 2026, by TC260 under CAC guidance) sits alongside binding verticals as a non-binding governance preview with no effective date or penalties. Built on Framework 1.0 (2024) and 2.0 (2025), it keeps the risk classification, technical response, and comprehensive governance logic and adds an agent layer for autonomous agents that execute tasks, alongside frontier, embodied-AI, and broader updates.
- 10
Framework 3.0 treats agent safety as a lifecycle concern, with Section 2.2.1 naming four categories in the framework wording: identity and permission misuse, reasoning and planning, tool invocation and execution, and memory storage. Annex 2 expands this to nine stages for reference: design and development, installation and deployment, instruction input, reasoning and planning, invocation and execution, memory storage, outputs, decommissioning, and residual risks. Listed failure modes include prompt injection in documents, emails, web pages, logs or messages, context overflow, goal hijacking, tool poisoning, tool privilege creep, tool selection bias, memory pollution, memory theft, leftover permissions and credentials, and escape from security constraints. Embodied AI is a separate new application-risk category in Section 2.2.2 covering perception, actuation, interaction, and multi-agent coordination.
- 11
Annex 1 application classification and risk grading by scenario, intelligence level, and scale with five tiers (low, general, relatively major, major, especially major), registration language for AI systems in critical information infrastructure, and open-source prohibited-use wording are carried over from Framework 2.0 and revised in 3.0, not newly introduced. Structurally new in 3.0 is Section 4.3 sandbox direction: industry-plus-risk rules to be written, sector-specific entry and testing for finance, education, broadcasting and television, and health, dynamic testing with monitoring and staged evaluation, a test-data sharing platform to be built, and cross-department recognition of results to be established. Section 4.3.3 only explores a liability-exemption mechanism for no-fault, controllable-risk sandbox conduct with four exclusions (national security harm, personal-rights infringement, major damage, intentional unlawful conduct) and names no body, procedure, or date, so no exemption is claimable. Explicit plus implicit content-ID traceability is binding labelling law from the 2025 measures and GB 45438-2025, referenced by the framework, not created by it.
Action Items for Governance and Compliance
How to make filing, assessment, labelling, and Annex 2 agent reference controls launch dependencies instead of fire drills.
Inventory algorithms and file early
A01Own a central registry of algorithms meeting filing characteristics with submission deadlines.
Generate filing dossiers (mechanism, purpose, data types) directly from system documentation.
Gate launches on security assessment
A02Make CAC assessment completion a hard release criterion for public-facing generative features.
Automate TC260-style red-team suites and corpus scans so assessment evidence is pipeline output.
Implement dual-layer content labels
A03Standardise explicit label formats and implicit metadata schemas platform-wide.
Apply visible marks at generation time and embed compliant metadata through every export path.
Prove training-data legality
A04License sources and maintain provenance logs with named approvers per corpus.
Keep contamination ratios measurable and reproducible against TC260 thresholds.
Ship user rights controls
A05Productize opt-out, label toggles, and targeting-off switches required by the 2022 provisions.
Serve algorithm summaries and objection channels as user-facing endpoints, not support tickets.
Harden AI agents for identity, tools, and memory
A06Assign a unique identifier per agent with no sharing across instances, minimum permissions for the current task with immediate credential revocation, a written high-risk operation list with human takeover and second confirmation plus rollback, and default refusal when approval fails or is silent, per non-binding Annex 2 reference.
Log file operations, command execution, network connections, skill calls, and payment transactions with tamper-resistant approval records, keep application run logs for not less than six months per Section 5.3.6, run credentials-in-memory, sandbox, and poisoning checks in CI, and map evidence to Section 2.2.1 and Annex 2 without treating it as a binding requirement.
Classify applications and use the sandbox path
A07Grade every application by scenario, intelligence level, and scale per Annex 1 (carried over from 2.0), flag CII deployments against carried-over registration language, and track future industry sandbox admission rules for novel or high-risk agents by sector.
Plan for sandbox evidence reuse across departments and compliant test-data use once rules and recognition procedures are written, and treat Section 4.3.3 exploration of exemption for no-fault, controllable-risk conduct as a signal with four exclusions (national security, personal rights, major damage, intentional acts), not a claimable shield.
Track Framework 3.0 and the horizontal AI law
A08Treat Framework 3.0 as a non-binding preview of future standards and track the mandatory agent safety standard drafting plus horizontal AI law consolidation drafts to re-map obligations as binding law lands.
Keep the obligation register config-driven so Annex 1 grades, Annex 2 agent duties, and new statutory duties attach to releases without re-architecture.
Engineering Translation
High-level capabilities that turn binding CAC obligations and non-binding Framework 3.0 agent reference duties into pipeline outputs.
>_Algorithm registry auto-generating CAC filing dossiers per system.
>_Red-team and corpus-contamination suites running in CI with immutable evidence.
>_Explicit watermarking plus metadata labelling enforced at generation and export.
>_Training-data licence and provenance ledger queryable per model version.
>_User-facing opt-out and algorithm-summary endpoints shipped by default.
>_Agent identity gateway with unique IDs, least-privilege scopes, and autonomy-tiered approvals per Annex 2 reference.
>_Tool-call and memory-write ledger with poisoning, privilege-creep, and pollution checks in CI.
>_Human-override and kill-switch paths with default-refuse and tamper-resistant audit trail per Annex 2 reference.
>_Annex 1-graded release gates (2.0 carried over) plus future sandbox evidence pack for cross-department recognition once procedures exist.
>_Obligation register keyed to regulation IDs so new rules map onto existing pipelines.
Delivered as capabilities, not paperwork
Each obligation above is translated into product-level engineering capabilities. The underlying stack and internal tooling are intentionally abstracted here; they are covered in technical briefings.
Educational summary only. This is not legal advice. Confirm obligations with qualified counsel for your jurisdiction.
Ship Filing-Ready and Agent-Safe AI Systems
Book a technical briefing to wire binding algorithm filing, security assessment, and dual-layer content labelling plus non-binding Framework 3.0 Annex 2 reference controls for agent identity, reasoning, tools, and memory into your China delivery pipeline.
