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DCC · DATA COMPLIANCE CHINA China data law, for overseas counsel.
§ TAG · ALGORITHM-FILING

Filed under algorithm-filing

Every brief tagged "algorithm-filing".

  • § 01 · AI-ETHICS-REVIEW

    Are Companies Ready for AI Ethics Review? A Practitioner's Guide to Committees, Expert Re-Review, and the Registration Platform

    AI ethics review has become a live issue: most algorithm- and AI-heavy companies applying to list in Hong Kong have recently received targeted regulatory inquiries on it. This practitioner's guide from 网安寻路人 walks through the regime built on MOST's 2023 Sci-Tech Ethics Review Measures and MIIT's 2026 AI Ethics Review Measures, starting with an 11-question FAQ. Its sharpest reading concerns Article 26 of the AI Measures, which waives expert re-review only where filing or registration already made ethics compliance a condition. The authors say they have seen almost no algorithm or generative AI filing that did, so algorithmic recommendation and deep synthesis providers, and generative AI filers and registrants, almost all still need full ethics review including expert re-review. On the committee, which is not mandatory because a Service Center can stand in, the guide calls for at least 7 members including an outsider, and advises against seating independent directors. It also covers registration on the national platform (within 30 days of setup, annual reports by March 31), the 30-day decision and re-review clocks, a 72-hour emergency track, the pilot Service Centers in ten provinces, and consequences that cross-refer to the Law on Progress of Science and Technology, the PIPL, the DSL, and the CSL.

    ai-ethics-review · ethics-committee · expert-re-review
  • § 02 · COMPUTE-CENTERS

    One Machine Room, Five Regulatory Identities: MaaS Compliance for China's AI Compute Centers

    AnJie Broad partners Cai Hang and Yao Ting and associate Liu Zeqiang argue that the IDC-era compliance checklist no longer fits the AI compute center. Their thesis: one machine room now carries five regulatory identities at once — domestic IDC operator, cross-border AI service provider, service exporter under the Export Control Law, supplier of self-deployed model capability, and responsible entity for the agents it ships — each with its own logic, and each transmitting obligations to the others. The brief works through value-added telecom licensing (B11/B12), energy-conservation review and PUE caps, the continuing duties under the Regulation on Network Data Security Management (State Council Decree No. 790), the token-export exemptions in CAC Decree No. 16 and what they do not exempt, the territorial limits of the GenAI Interim Measures, the Export Control Law catch-all, the unsettled line between large-model filing (备案) and large-model registration (登记), open-weight license trigger clauses, and the criminal exposure that follows an agent's tool calls under Criminal Law Article 285.

    compute-centers · intelligent-computing-center · maas
  • § 03 · AI-COMPANION

    Ten Questions Before July 15: A Compliance Q&A on China's AI Anthropomorphic Interaction Measures

    Two days before the Interim Measures for the Management of AI Anthropomorphic Interaction Services take effect on July 15, 2026, compliance practitioners Chen Huan and Li Qiyao distill the final text into ten questions AI companies keep asking: what counts as an anthropomorphic interaction service (and what is excluded), the content red lines, training-data duties, mandatory registration fields including age and emergency contacts, the two-hour usage reminder, the ban on virtual intimate relationships for minors, the separate-consent gate on training with sensitive interaction data, the five security-assessment triggers, and the penalty ladder topping out at RMB 200,000 where life and health are harmed.

    ai-companion · anthropomorphic-interaction · minors-protection
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