The classification screen

4 questions before you choose the route.

This page identifies the right question and evidence. It does not determine the legal outcome on a reader’s facts.

01

Is the algorithm public-facing in China?

Feed, search, recommend, price display.

Public
02

What type is it under current CAC lists?

Recommendation vs GAI vs other.

Type
03

Have user controls been built?

Opt-out of targeting, explanation.

Controls
04

Is PIPL ADM also in play?

Scoring people.

PIPL

Working rule: CAC rules on recommendation algorithms require many public-facing ranking, recommendation and similar engines to file, publish user-control mechanisms, and meet content and labour-style fairness duties.

What changes the answer

The signal ledger.

These facts move the question beyond a label and into a product, money-flow and control analysis.

Signal
Ask the operating question
Why it changes the route
Guide use
Are you rewriting the consumer-digital article?
Additional facts can change the Data Privacy & Cybersecurity route, evidence and next step.
ISO certificate
Did a vendor sell ‘algorithm certified’?
Wrong scheme.
Silent recs
No filing, no user switch.
Classic gap.
Prepare before you escalate

Bring a compact evidence docket—not a pitch deck.

Give a compliance team or counsel the operating facts that reveal the perimeter.

01Product listWhich engines rank or recommend to PRC users.
02Current filing rulesDated CAC measures and portal notes.
03User-control screenshotsWhat people can turn off.
Common confusions

Questions people ask before they build.

Short answers for orientation. The right result can change with the service model and current rules.

Does every ML model need filing?

No. The regime targets specified public information-service algorithms. An internal demand-forecast model is a different story.

Where is the long guide?

Keep using /china-consumer-digital-compliance-algorithm-pipl for the national narrative. This page is the focused filing definition.

Primary authorities

Reviewed sources support orientation, not a fact-specific assessment.

PIPL / DSL / CSL (NPC laws database)
Cyberspace Administration of China
Gov.cn policy releases
National laws database (NPC)