China publishes consolidated filings for generative AI services

Background

Generative AI services offered to the Chinese public go through a filing (备案) step under the Interim Measures for the Management of Generative AI Services. Filing means the provider registers information about the service with the cyberspace administration, and the service then appears on a public record. Providers of services with public opinion attributes or social mobilisation capacity file through the cyberspace administration of the locality where they are registered^[1].

What was announced

On 2 April 2024 the Cyberspace Administration of China announced that it would publish information on generative AI services that had completed filing under the Interim Measures^[1]. The point of the announcement was disclosure: instead of the filing remaining an internal administrative record, the set of filed services would be made visible to anyone who wanted to look.

How the register is published

Publication runs on two levels. Local cyberspace administrations publish the filed information for services in their own areas, and the national administration keeps a consolidated list on its website, updated regularly^[1]. The two levels fit together: the local notices are the primary records, and the national list gathers them into one place that a reader can consult without knowing which province a given company registered in.

The display duty

The announcement also set a requirement aimed at the products people actually use. A generative AI application or feature that has already been launched must show, in a prominent place or on the product detail page, the filed generative AI service it uses, including the model name and the filing number^[1]. The practical effect is that a product's own pages state which model sits behind it and what that model's filing number is, so the claim can be matched against the published list rather than taken on trust.

What the consolidated list shows

On the consolidated list, the earliest filings carry filing numbers with the date code 20230821^[2]. The services with that code are Baidu's WenXinYiYan, Zhipu's ChatGLM, ByteDance's YunQue, Baichuan's BaiYing, the Chinese Academy of Sciences' ZiDongTaiChu, MiniMax's abab, SenseTime's RiRiXin and the Shanghai AI Laboratory's ShuSheng^[2]. The same list records iFlytek's XingHuo with the code 20230823, 360's ZhiNao with 20230831 and Alibaba's TongYiQianWen with 20230901^[2].

Filing numbers follow a fixed pattern of locality, model name and date code, such as Beijing-WenXinYiYan-20230821^[2]. The number therefore carries three pieces of information at once: where the provider filed, which model is covered, and the date code attached to that filing. Because the same number must be displayed in products, it works as a short identifier that links an app on a phone to an entry on the national list.

Why it matters

The filing system produces a public register of generative AI services, and the display requirement connects that register to the products in circulation: the list says which models are filed, and a product's detail page says which of them it uses^[1][2]. For a reader, the two together make it possible to check, without reading the underlying rules, which model a given application relies on and whether that model appears among the filed services. The consolidated list is updated regularly, so it also functions as a running record of services added over time rather than a one-off snapshot^[1].