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

Filed under algorithm-filing

Every brief tagged "algorithm-filing".

  • § 01 · 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
  • § 02 · 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
§ SUBSCRIBE

The Monday brief.

One short email every Monday. New briefs on Chinese data-compliance rules from the previous week, with the source law cited.

Opt-in only. Unsubscribe anytime by replying "unsubscribe" to any issue.

SUPPORT DCC

Keep the publication free to read. Suggested support is $19.99, or choose your own amount.

Support →