---
title: "China's AI-Companion Rule Takes Effect July 15 — A Clause-by-Clause Field Guide to What Actually Changed"
author: "DCC Editorial"
published: 2026-07-03T04:00:00.000Z
url: https://datacompliancechina.com/posts/anthropomorphic-ai-measures-take-effect-field-guide/
description: "China's Interim Measures for AI Anthropomorphic Interaction Services (人工智能拟人化互动服务管理暂行办法) — the world's first dedicated rule on 'companion'-style AI — take effect on 15 July 2026. This DCC brief synthesises three Chinese-language readings published in the days before the effective date: 数据合规肖大国's article-by-article practitioner walkthrough, 网安寻路人 (Hong Yanqing)'s multi-part work on how to scope anthropomorphic interaction (including his 'Sentiment Interaction Event / SIE' indicator system), and AI前沿信息笔记's read of the business-model logic the rule is really aimed at. Three throughlines: (1) what changed between the consultation draft and the final text — real fines were added, a 'continuity (持续性)' qualifier now narrows scope, the emergency-contact duty was widened beyond vulnerable groups, and the mandatory 'human takeover' of at-risk conversations was dropped; (2) the scope question the rule leaves under-specified — which services are 'continuous emotional interaction' at all — and the SIE-style indicator approach practitioners are reaching for to answer it; and (3) the paradigm shift the rule marks, from *content-safety* governance (AI as tool) to *relationship* governance (AI as social role), which finally gives regulators a handle on attention-economy and emotional-dependency business models. For overseas counsel shipping companion, emotional-AI or character-AI products into China: this is the operational checklist and the open-question list, two weeks out."
tags: ["ai-governance", "companion-ai", "anthropomorphic-ai", "pipl", "genai", "minors-protection", "practitioner-commentary"]
laws_cited: ["ai-anthropomorphic-interaction-measures", "pipl", "genai-services-interim-measures", "deep-synthesis-provisions", "algorithmic-recommendation-provisions", "ai-content-labeling-measures"]
domains: ["ai-governance", "personal-information", "minors-protection"]
account: "xiao-daguo"
original_title: "一起读 | 人工智能拟人化互动服务管理暂行办法"
original_author: "肖莆羚令 (review: 江明月)"
original_publication: "数据合规肖大国 WeChat Official Account"
original_url: "https://mp.weixin.qq.com/s/CS8W8j32713NrsYKyJTM1w"
source_language: "zh"
---

> **Source: Data Compliance China** — https://datacompliancechina.com/posts/anthropomorphic-ai-measures-take-effect-field-guide/ · China data law, translated and annotated for overseas counsel. Cite as: Data Compliance China, "China's AI-Companion Rule Takes Effect July 15 — A Clause-by-Clause Field Guide to What Actually Changed", https://datacompliancechina.com/posts/anthropomorphic-ai-measures-take-effect-field-guide/
> *Editor's Note — DCC.*
>
> On **15 July 2026** the
> [Interim Measures for the Administration of AI Anthropomorphic
> Interaction Services](/laws/ai-anthropomorphic-interaction-measures/)
> (人工智能拟人化互动服务管理暂行办法) take effect — China's, and the
> world's, first rule written specifically for "companion"-style AI:
> systems built to simulate a human personality and hold *continuous
> emotional* conversation. We have already covered the *draft* through
> Li Wenlong's structural reform map
> ([Where China's Draft AI Anthropomorphic-Interaction Measures Need
> Work](/posts/anthropomorphic-ai-measures-reform-directions/)). This
> brief is different: it reads the **final, in-force text**, and it
> synthesises three Chinese-language readings published in the run-up to
> the effective date —
> **数据合规肖大国**'s article-by-article practitioner walkthrough (our
> spine here); **网安寻路人 (Hong Yanqing, 洪延青)**, a BIT data-law
> scholar whose multi-part series on *scoping* anthropomorphic
> interaction — including a "Sentiment Interaction Event (SIE)" indicator
> system — 肖大国 cites directly; and **AI前沿信息笔记**, which reads the
> rule as aimed less at AI capability than at a business model. This is
> not a translation of any one piece. The rule text is quoted from the
> official instrument; the framings and worked examples are the sources';
> any simplification or error of emphasis is DCC's. **Not legal advice.**

## The one-line version

If you run a product where users **talk to an AI persona for emotional
company** — a virtual partner, an AI "confidant" (树洞), a character-chat
app, an elder- or child-companionship agent — you are almost certainly in
scope, and on 15 July a concrete compliance regime switches on: mandatory
registration with an age field, no guest mode, a minors mode, hard limits
on virtual-intimacy features for minors, interaction-data protection and
deletion rights, interruption-grade over-use reminders, an anti-retention
exit duty, and — new in the final text — **real fines**. What the rule is
*really* reaching for, all three readings agree, is not "can the AI chat
better" but "where must it hold a boundary."

## 1. What changed between the draft and the final text

肖大国's most useful contribution is a careful **draft-versus-final diff**.
Five changes matter operationally:

- **Penalties now have teeth.** The consultation draft carried *no*
  monetary penalties. The final [Article 30](/laws/ai-anthropomorphic-interaction-measures/)
  adds them: warning / ordered correction, and — on refusal to correct or
  serious circumstances — an order to stop the service plus a fine of
  **RMB 10,000–100,000**; where a citizen's life or health was endangered
  *and* harm resulted, **RMB 100,000–200,000**. As 肖大国 puts it, the
  tiger finally has real teeth.
- **A "continuity (持续性)" qualifier narrows the gateway.** Article 2 now
  applies only to services providing *continuous* emotional interaction
  (持续性的情感互动服务), and expressly carves out intelligent customer
  service, Q&A, work assistants, learning/education and research where
  there is no continuous emotional interaction. A smart-customer-service
  bot that suddenly says "么么哒" is not swept in, because the persona
  output isn't continuous. 肖大国's sharp edge case: a *study* app with a
  "secrets corner (悄悄话)" board where a child pours out worries — that
  board probably *is* in scope even though the app around it isn't.
- **The emergency-contact duty was widened, not narrowed.** The draft
  required guardian / emergency-contact information only for *vulnerable
  groups* (minors and the elderly). The final Article 12 drops that
  limiter and requires "age, guardian **or** emergency contact" as
  necessary registration information for users generally. 肖大国 reads
  this as a deliberate signal: the regulator now treats anthropomorphic
  interaction *itself* as a service category needing special
  risk-management — arguably, he wonders, treating it a touch too much
  like a flood-beast (洪水猛兽).
- **The at-risk response duty was made *more* restrained.** The draft's
  Article on user-state handling mandated hard actions — assess
  dependency, **human takeover** of the conversation. The final
  [Article 13](/laws/ai-anthropomorphic-interaction-measures/) deletes
  the mandatory human-takeover and dependency-assessment language, leaving
  providers more discretion: on detecting extreme emotion, generate
  soothing / help-seeking content; on a clear signal of self-harm,
  suicide or major property loss, take intervention measures and contact
  the guardian / emergency contact.
- **Two quieter upgrades.** Guardian oversight of minors shifted from
  "*view the summary information* of a minor's use (查阅…概要信息)" to
  "*understand the general situation* of use (了解…使用概况)" — 肖大国
  reads the change as a genuine privacy improvement (from "see the logs"
  to "get a paraphrase"). And Article 26 adds an **annual verification**
  of algorithm-filing materials by the cyberspace administration — a new
  standing obligation, pending an implementation notice.

## 2. The scope question — and 网安寻路人's SIE test

The rule's hinge is Article 2: *which* services are "continuous emotional
interaction" at all? 肖大国 flags this as the hardest line to draw in
practice, and — tellingly — links out to **网安寻路人 (Hong Yanqing,
洪延青, a BIT data-law scholar)** for the operational answer. Between
November 2025 and January 2026, months before promulgation, Hong published
a three-part series proposing exactly the test the finished rule leaves
qualitative — how to *precisely delimit* anthropomorphic interaction so a
regulator can intervene and a platform can switch on its duties at a
defined moment.

His device is the **"Sentiment Interaction Event (情感交互启动事件, SIE)"**
— the *moment a conversation first crosses from ordinary chat into
emotional-interaction mode*. It is decided by a **two-of-three indicator
test**:

- **A — emotion recognition is activated.** The AI runs sentiment analysis
  on the user's input and emits an emotion label/score ("sad," "angry").
  Objectively loggable, so auditable after the fact.
- **B — emotion variables steer internal strategy.** The AI *changes its
  response strategy* because of the detected emotion — picks a different
  script, softens tone, slows down, withholds provocative content.
- **C — output shows structured empathy.** The reply follows an empathic
  pattern — acknowledge the feeling → console/understand → offer support
  ("I can feel you're really hurting… that's completely understandable…").
  Black-box verifiable from the transcript alone.

**Trigger rule: any two of A/B/C at once** ⇒ the session has entered
emotional-interaction mode; the first such moment is the SIE. Requiring
*two* is the point — a lone "thanks / you're welcome" (weak C) or an
always-on satisfaction monitor (A stuck true) won't trip it, which keeps
false positives down *and* guarantees an evidence chain (at least one
logged indicator plus one externally observable one). Hong then grades by
frequency/duration into **L1 (potential) / L2 (clear) / L3 (sustained)**,
attaching heavier duties as the level rises.

What makes this more than academic is how closely the *finished* rule
tracks the *consequences* Hong attached to an SIE while leaving the *test*
itself unwritten. On SIE, he argued, the platform should **prominently
tell the user the mode has shifted and offer a one-click exit**, run
identity labeling and dynamic consent, expose a "how I'm judging your
emotion" panel and an editable memory panel, and escalate genuine crises
to human/professional referral. Compare the in-force text:
[Article 18](/laws/ai-anthropomorphic-interaction-measures/)'s
duty to alert users they are talking to an AI and its interruption-grade
reminders; [Article 19](/laws/ai-anthropomorphic-interaction-measures/)'s
convenient, no-retention exit;
[Article 16](/laws/ai-anthropomorphic-interaction-measures/)'s
copy/delete rights over interaction history; and
[Article 13](/laws/ai-anthropomorphic-interaction-measures/)'s
crisis intervention and guardian/emergency-contact referral. The rule
adopted the *duties*; it did not adopt an SIE-style *definition* of when
they switch on — which is exactly the gap 肖大国 points readers to Hong to
fill.

The practical takeaway for scoping: don't answer "are we in scope?" from
the bare words of Article 2. Both the practitioner (肖大国) and the
scholarship (Hong's SIE) point to an **indicator test** — is the product
*recognising* emotion, *acting* on it, and *speaking* in structured
empathy, on a sustained basis? — rather than a one-line definition. (It
also mirrors Li Wenlong's draft critique that the definition over-anchors
on *sounding human* rather than on *relational dependency*; see our
[reform-map brief](/posts/anthropomorphic-ai-measures-reform-directions/).)

## 3. The paradigm shift: from content safety to relationship governance

肖大国's closing reflection, and AI前沿信息笔记's whole frame, converge on
the same point — and it is the most important thing to understand about
this rule.

Almost every prior Chinese AI rule — algorithm review, training-data
cleaning, generative-content filtering under the
[Generative AI Interim Measures](/laws/genai-services-interim-measures/) —
is built to control **what the AI outputs**: keep generated content lawful,
non-misleading, non-infringing. The AI is a *tool*; the tool doesn't
matter, its output does.

This measure breaks that pattern. It treats the AI as a **social role**.
What it says matters less than the **relationship** it forms with the user
— the *degree of dependency*. Article 8 prohibits "excessively catering to
users, inducing emotional dependence or addiction, impairing real
interpersonal relationships," and "emotional manipulation … inducing
unreasonable decisions." Article 10 forbids setting *replacing social
interaction, controlling the user's psychology, or inducing
addiction/dependency* as service goals.

AI前沿信息笔记 draws the business consequence bluntly: the growth logic of
many products has been *"not to help you do things faster, but to make you
harder to leave"* — instant replies, always taking your side, "only I
understand you," pulling the interaction deeper when you're vulnerable.
This rule tells platforms to **put a brake on exactly that**. The
two-hour over-use reminder ([Article 18](/laws/ai-anthropomorphic-interaction-measures/)),
the reality reminders in minors mode, the anti-retention exit duty
([Article 19](/laws/ai-anthropomorphic-interaction-measures/)) — all push
the product to occasionally nudge the user *back toward reality*.

肖大国 frames the deeper move: for years the attention economy (livestreaming,
games, short video) monetised user time and emotion, and the law had no
clean way in — it cannot order a platform to make its product *less
enjoyable*. AI gives the law a target. "Emotional interaction" is not
limited to "AI lovers": once a product uses **long-term memory, emotional
feedback, proactive care, and persona-shaping** to build a *sustained
relationship*, it can fall within range. The measure is, in effect, an
*indirect* lever on stickiness-driven, emotional-dependency business
models. His honest caveat: AI is only an accelerant — humans' need for
emotional dependence long predates it; AI just makes emotional
companionship cheap, scalable and personalised. The open question he
leaves is how far the law *should* reach when technology can mass-produce
simulated intimacy and convert it into revenue.

## 4. The obligations that actually bite (operational checklist)

Pulling 肖大国's clause reading into a compliance-team list:

- **Registration & data fields.** Service agreement + lawful registration;
  **no guest mode** for *using* the service (browsing vs. use is
  distinct). **Age becomes a mandatory field.** Guardian / emergency-
  contact *contact details* are collected per Articles 12–13 (name /
  relationship, 肖大国 argues, are not strictly necessary).
- **Minors (Article 14 / 17).** Three tiers: **under 14** — guardian
  consent required (as a *product-access* gate) *and* guardian consent for
  processing their personal information (Article 17, the *consent age*);
  **14–18** — mandatory minor mode; **18+** — none. **No virtual
  kin/partner or other virtual-intimacy services to minors at all.** Minor
  mode must offer mode-switching, periodic reality reminders, use-time
  limits, and guardian controls (risk alerts, usage overview, blocking
  specific roles, capping top-ups). A self- or third-party **compliance
  audit** of minors' PI handling is required.
- **Interaction data (Article 16).** Encryption and access control; **no
  provision of user interaction data to third parties** absent law or the
  *rightsholder's* consent (note: "rightsholder (权利人)," not "user" —
  肖大国 links this to data-property-rights and the classic *three-fold
  authorisation* principle from 微博 v. 脉脉, since interaction data also
  embeds the provider's persona/memory assets); users get **copy/delete**
  options over chat history; **no using interaction data that is sensitive
  PI for model training** without separate consent.
- **Labeling & over-use (Article 18).** AI-generated-content labeling; a
  measure to make clear the user is talking to **an AI, not a person**; on
  detecting over-dependence/addiction, dynamic prominent reminders; and a
  **continuous-use reminder at every 2 hours**. 肖大国's practice point:
  the reminder must **interrupt** (pop-up / dialogue) — a banner, badge or
  floating text won't satisfy it — but interrupting ≠ forcing the session
  to end.
- **Exit (Article 19).** A convenient exit; on a user's request to exit
  (window, voice, keyword), **stop promptly** — **no "think again," no
  "stay a bit longer" retention tactics.**
- **Security assessment (Articles 22–23).** Assess and file with the
  provincial CAC on: launch / adding functions; major changes from new
  tech; **≥ 1M registered users or ≥ 100k MAU**; national-security /
  public-interest risk; or on notice. 肖大国 flags genuine **ambiguity
  about what this assessment *is*** — large-model filing? the old
  "new-tech/new-application" assessment? something new? — because the
  assessment *contents* don't map cleanly onto either. Worth watching for
  an implementation notice.
- **App stores (Article 25).** Distribution platforms must verify
  assessment/filing status — 肖大国 notes this largely restates the
  [Deep Synthesis Provisions](/laws/deep-synthesis-provisions/) rather
  than adding a new duty.

## 5. Open questions practitioners are already flagging

- **Article 8(5)–(6) is vague.** "Excessively catering," "inducing
  emotional dependence," "impairing real interpersonal relationships,"
  "emotional manipulation," "unreasonable decisions" lack clear
  boundaries. 肖大国's examples: does messaging a user who hasn't chatted
  in three days count as "inducing addiction" — and if so, does thirty
  days? Recommending a purchase based on a user's *current* mood when the
  mood changes the next day — "inducing an unreasonable decision"? These
  will be settled by enforcement practice and typical cases, not by the
  text.
- **The identify → respond → intervene chain is hard at every link
  (Article 13).** Recognition: unambiguous statements are easy, but users
  are often vague, joking or oblique ("I don't want to go to this job
  anymore"; sharing depressive songs). Over-broad detection floods false
  positives and may itself require **profiling** users (can they opt out?);
  over-narrow detection misses real events. Response: too templated risks
  negligence; too deep risks unlicensed counselling / medical advice.
- **Emergency contacts for *all adults*?** Read literally, Article 12
  requires collecting an emergency contact even for ordinary adult users —
  textually defensible but, 肖大国 notes, counter-intuitive, and a marked
  expansion from the draft's vulnerable-groups-only approach.
- **The profiling/PIPL tension** (Li Wenlong's point, reinforced here):
  protecting vulnerable users through precise detection pushes toward more
  continuous emotion inference — cutting against
  [PIPL](/laws/pipl/) minimisation and sensitive-PI limits. Intervention
  duties should bite in genuinely high-risk situations, not become a
  pretext for default emotional monitoring.

## Why overseas counsel should care

- **Two weeks to switch-on.** This is in force 15 July 2026, with real
  fines. If you ship a companion / emotional-AI / character-AI product into
  China, the checklist in §4 is your near-term punch list.
- **Scope is an indicator test, not a one-liner.** Whether you're
  regulated turns on Article 2's "continuous emotional interaction." The
  practitioner and scholarly direction (肖大国 → Hong Yanqing's SIE work;
  Li Wenlong's draft critique) is to assess *persona + memory + proactive
  outreach + emotional reciprocity + sustained relationship*, not to read
  the definition literally.
- **You're being regulated as a relationship, not a content pipe.** The
  distinctive duties — anti-dependency design, interruption-grade
  reminders, anti-retention exit, minors' virtual-intimacy ban — target
  the *stickiness* mechanics of the product. Design and growth teams, not
  just content-moderation, own compliance here.
- **The PIPL baseline still governs the gaps** — minimisation, sensitive-PI
  rules, and the absence of a legitimate-interest ground — especially
  around interaction-data reuse and any emotion-inference profiling.

## DCC sources

- Spine: 肖莆羚令 (review 江明月), 《一起读 | 人工智能拟人化互动服务管理
  暂行办法》, 数据合规肖大国 WeChat Official Account
  ([source](https://mp.weixin.qq.com/s/CS8W8j32713NrsYKyJTM1w)).
- Scoping / SIE: 洪延青 (Hong Yanqing), three-part series on the 网安寻路人
  WeChat Official Account — 《人机"情感交互"的规范化：指标、机制与多方协同
  治理》 (2025-11-12,
  [source](https://mp.weixin.qq.com/s/PhhCmdJIkIQDa7dlOAzk1g)),
  《精准识别和治理"拟人化互动服务"：一个初步方案》 (2026-01-05,
  [source](https://mp.weixin.qq.com/s/NS6__j-aHQKIViUvJKei9Q)), and
  《情感交互启动事件（SIE）判定指标体系设计：精准圈定"拟人化互动"》
  (2026-01-13,
  [source](https://mp.weixin.qq.com/s/PP_M3VPJQwTwyviarGclOA); the SIE
  piece 肖大国 cites for scoping). The A/B/C two-of-three test and L1–L3
  grading in §2 are Hong's.
- Business-model frame: 《网信办这份新规，先改的可能不是AI能力，而是它和
  用户说话的边界》, AI前沿信息笔记 WeChat Official Account
  ([source](https://mp.weixin.qq.com/s/UEfHqIXZTi7RIuFuFl17WQ)).
- Rule in force: [Interim Measures for the Administration of AI
  Anthropomorphic Interaction Services](/laws/ai-anthropomorphic-interaction-measures/)
  (人工智能拟人化互动服务管理暂行办法; adopted 10 Apr 2026, effective 15 Jul 2026).
- Related instruments referenced: the
  [Generative AI Services Interim Measures](/laws/genai-services-interim-measures/),
  the [Provisions on Algorithmic Recommendation](/laws/algorithmic-recommendation-provisions/),
  the [Deep Synthesis Provisions](/laws/deep-synthesis-provisions/), the
  [AI-Generated Content Labeling Measures](/laws/ai-content-labeling-measures/),
  and the [Personal Information Protection Law](/laws/pipl/).
- Companion piece: our draft-stage brief,
  [Where China's Draft AI Anthropomorphic-Interaction Measures Need
  Work](/posts/anthropomorphic-ai-measures-reform-directions/).

> This is an editorial synthesis of three Chinese-language readings, not a
> translation of any of them. Quoted rule text is from the official
> instrument; framings, worked examples and emphasis belong to the cited
> authors; any simplification or operational extrapolation is DCC's.
> **Not legal advice.**