Direct answer

Public generative-AI services are a CAC regime — a foreign API does not put you outside it.

CAC interim measures on generative AI, plus labelling, corpus and deep-synthesis rules, target services that offer GAI to the Chinese public. Providers face training-data, security-assessment, filing, and content-moderation duties. Users who integrate a foreign model into a China-facing product can still be providers. PIPL still applies to prompts and logs that are PI. Algorithm filing is a sibling overlay for recommendation engines. The live consumer-digital/algorithm guide stays the long national piece — this wiki page is the GAI definition. Do not freeze a filing-portal URL here.

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 service offered to the PRC public?

App, site, API wrapper, WeChat.

Public
02

Are you a provider or a deploy-only user?

Who presents the model.

Role
03

Do prompts contain PI?

PIPL plus GAI.

PI
04

Is there an algorithm-filing overlay?

Recommendation + GAI.

Filing

Working rule: Map the regulated role before marketing or launch in China.

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
Offshore API myth
Did legal say ‘OpenAI is foreign so CAC does not apply’?
China-facing provision can still be in scope.
Internal copilot only
Staff tool vs public bot.
Internal use is a lighter story but not a PIPL skip.
Unlabelled synthetic media
Deep-synthesis labelling duties.
Separate overlay.
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 descriptionWho can use it, in which language/market.
02Model and corpus notesWhat is trained or called.
03PIPL mapPrompts, logs, export of chats.
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 this replace the consumer algorithm guide?

No. /china-consumer-digital-compliance-algorithm-pipl stays the long guide. This is the GAI wiki definition.

Do we file before launch?

Public GAI services typically need security assessment/filing under current CAC measures. Confirm the current list — do not launch on a wiki guess.

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)