The BGA China Team, led by Haiying Yuan, recently wrote an update on China’s draft regulation for generative artificial intelligence.


  • The Cyberspace Administration of China (CAC) published a draft regulation for generative AI on April 11. The draft provides rules on the use and research and development of generative AI services offered to the public within Chinese territory.
  • The draft regulation addresses key global concerns surrounding AI, including data protection, nondiscrimination bias and the quality of training data. The draft requires that AI-generated content be true and accurate, a standard many experts argue current technology cannot meet.


  • The CAC’s draft embodies China’s growing national security strategy, which prioritizes technological self-reliance and data security and closes off certain opportunities for foreign investment. The draft provides stringent rules on the algorithmic functions of generative AI products and requires companies to apply for security reviews for their AI products to enter the Chinese market.
  • The draft sets the global tone on AI regulation by placing virtually all responsibility on providers and none on users. Some experts in China argue this standard could be more balanced, and future revised versions of the draft may take this into account.


  • The regulation could drive an industrial AI boom in China, but it could also prevent domestic firms from competing with Western ones. The regulation aims to strictly control the data that firms use to train generative AI, which would prevent Chinese AI products from becoming as advanced as Western products.
  • The draft regulation could pave the way for AI-generated products to propel China’s software-as-a-service market. AI products that align with Beijing’s national agenda of technological resilience, enhanced digitization, private sector innovation and robust health care delivery could flourish under the new regulation. As such, foreign businesses may find that AI in China will have narrow industrial applications, unlike the potentially wide-ranging uses in Western markets.

We will continue to keep you updated on developments in China as they occur. If you have any comments or questions, please contact BGA Adviser Eric Wang at

Best regards,

BGA China Team