China TMT: Annual Review of 2024 and Outlook for 2025 (I)

In 2024, regulatory reforms in China’s Technology, Media, and Telecommunications (“TMT”) sector were in full swing. On the Artificial Intelligence (“AI”) front, governance efforts gained traction, new policies and standards providing not only continuity with existing legislation but also clear direction for how AI can be applied and integrated across industries. At the same time, China’s telecommunications sector entered a new phase of opening-up and high-quality growth, expanding the range of products and services in the information and communications market. These changes are fuelling corporate innovation, improving service quality, and strengthening the industry’s international competitiveness. Elsewhere in the TMT landscape, rapid developments in areas such as new energy vehicles (“NEVs”), intelligent connected vehicles (“ICVs”), online sales, and internet advertising are driving more diverse regulatory priorities. This wave of innovation is helping to refine and modernise the regulatory framework to keep pace with emerging challenges and opportunities.

As we head into 2025, what are the new opportunities and challenges for businesses? In the following two-segment series, we’ll delve into the key developments across the TMT sector in 2024 and explore how they are likely to shape the landscape in 2025.

We will highlight our observations on major regulatory and enforcement developments in the TMT sector in 2024 through the following six key sections:

• AI Governance: Regulatory updates in AI governance during 2024 have primarily focused on the refinement of policy guidance and standards. On one hand, authorities such as the Cyberspace Administration of China (“CAC”) have introduced a series of policies and standard frameworks aimed at driving the implementation and enforcement of existing regulations. At the same time, the emergence of the first infringement cases involving AI applications in various areas has provided valuable precedents that will inform future legislative efforts. On the other hand, the integration of AI across industries and international collaboration has become a key focus for development. With the ongoing progress in the filing of algorithms and large language models (“LLMs”), the development and application of related technologies are now operating within a more structured and compliant framework.
• Empowering the Telecommunications Industry: One of the most notable developments in the telecommunications industry in 2024 was the expanded opening-up of value-added telecommunication services. The Ministry of Industry and Information Technology (“MIIT”) announced the removal of foreign ownership restrictions in pilot regions for services such as Internet Data Centres (“IDC”) and Content Delivery Network (“CDN”). This move is expected to attract greater foreign investment into the Chinese market while fostering the diversification of technologies and services. At the same time, a series of policies and initiatives were introduced to enhance telecommunication infrastructure development and promote the high-quality growth of basic telecommunication services.
• The NEVs and ICVs: Policy support has injected fresh momentum into both industries, with regulatory priorities differing between the two. From one angle, the introduction of various infrastructure projects and supportive policies has accelerated the development of NEVs and ICVs. From a different angle, regulatory efforts in the NEV sector have focused on battery utilisation and safety, while enforcement in the ICV sector has centred on pilot projects and the standardisation of autonomous driving technologies. With the synergy of policies and regulations, both industries are poised to face new opportunities and challenges in the future.
• Online Sales: In the online sales sector, central authorities have strengthened regulations to enhance consumer protection and combat unfair competition, ensuring a fair and transparent market environment. At the local level, governments have introduced supportive policies to promote the growth of livestreaming e-commerce and instant retail, diversifying sales models and service offerings. Meanwhile, rural e-commerce and cross-border e-commerce have been identified as key areas for development, with policies aimed at revitalising rural economies and boosting international trade. On the enforcement side, the National Medical Products Administration has intensified efforts to crack down on illegal online sales of pharmaceuticals and medical devices, strengthening regulatory oversight in the sector.
• Standardisation of Internet Advertising: From one perspective, the State Administration for Market Regulation (“SAMR”) has issued guidelines to refine advertising labelling rules, requiring clearer identification of internet ads through text, voice, and other means. The guidelines also include provisions for AI and deep synthesis technologies, aiming to drive the development of technical standards. From the other perspective, in 2024, a nationwide campaign was launched to tackle advertisements in livelihood areas such as healthcare, pharmaceuticals, and food, with the goal of promoting more regulated industry practices.
• Digital and Intelligent Transformation of Industry: In this area, the MIIT and relevant departments have released several implementation plans and action guidelines covering various sectors, including industrial internet, the Internet of Things (“IoT”), industrial robots, and equipment upgrades. These initiatives aim to drive the digital and intelligent transformation of industries such as manufacturing, power, photonics, and raw materials. Additionally, the release of pilot projects, case studies, and supporting policies has provided valuable reference scenarios and a favourable external environment for the transition to new industrialisation.

In this first article, we give an overview of key legislative and enforcement developments in the TMT sector in 2024, focusing on AI governance, empowering the telecommunications industry, and the NEVs and ICVs sectors, along with a preview of what to expect in 2025.

Part I: AI Governance

In 2024, AI governance in China favoured a balanced approach, focusing on both regulation and development. From one perspective to ensure the implementation of existing AI regulatory requirements, the CAC and other departments have released a series of policy documents and standard frameworks. These aim to provide more specific and practical technical guidance and behavioural norms in areas such as AI service safety and AI content labelling. These policies not only address technical requirements but also regulate responsible entities like businesses, ensuring that AI technologies are safeguarded in terms of both security and ethics. On the contrary, the MIIT, the State Council, and local governments have been actively promoting the application and integration of AI across industries such as healthcare, manufacturing, and urban development, driving economic transformation and growth. Meanwhile, international collaboration has become a key theme in China’s 2024 AI governance. China has actively participated in the development of international AI governance frameworks, sharing technologies and experiences to jointly tackle the challenges and opportunities posed by AI.

1. Regulatory developments

1) Multiple policies and standards drive implementation of existing regulations

Following the introduction of the Interim Measures for the Administration of Generative AI Services (“Generative AI Measures”) in 2023 (See our views here and here), one of the key challenges for the development of AI-related industries has been how to implement a series of regulatory requirements, including the Generative AI Measures, the Provisions on the Administration of Algorithm-generated Recommendation  for Internet Information Services, and the Provisions on the Administration of Deep Synthesis of Internet-Based Information Services, as well as how to determine effective compliance measures. In response, the CAC and the National Technical Committee 260 on Cybersecurity of Standardisation Administration of China (“TC260”) have released several policies and standard frameworks to support the implementation of existing regulations.

In September 2024, the CAC released the Measures for the Labelling of AI-Generated Synthetic Content (Draft for Comments), outlining the types and requirements for labelling such content. It also clarified the responsibilities of distribution platforms in managing these labels. On the technical front, the CAC also issued the Cybersecurity Technology – Methods for Labelling AI-Generated Synthetic Content (Draft for Comments) as a forthcoming mandatory national standard, which provides detailed guidelines on the technical implementation of various labels. This aims to offer clearer direction for both content generation and distribution service providers.

Additionally, in March 2024, the TC260 released the Basic Security Requirements for Generative AI Services (TC260-003) as a technical guide to support the Generative AI Measures. The document outlines detailed security requirements for various stakeholders involved in generative AI services across multiple dimensions, as well as specific guidelines for security assessments. Subsequently, the TC260 drafted the Cybersecurity Technology – Basic Security Requirements for Generative AI Services (Draft for Comment), which supplements and refines the previous document as a recommended national standard. In December, the TC260 also sought feedback on the national standard Cybersecurity Standards Practice Guidelines: Security Emergency Response Guidelines for Generative AI Services, aimed at guiding companies providing generative AI services in preparing for security emergencies and enhancing their ability to respond to cybersecurity incidents.

Although most of these standards and regulations are still in draft form, it is clear that more detailed operational guidelines will provide businesses with clearer direction for compliance efforts. The ongoing refinement of these standards and policy frameworks reflects the regulators’ focus on promoting the development of AI technologies in a manner that is regulated, safe, transparent, and trustworthy.

2) Government drives AI application and integration across industries

Government bodies at all levels have taken various measures to promote the integration and application of AI across industries. In June 2024, the MIIT, the CAC, and two other departments together issued the National AI Industry Standardisation System Construction Guidelines (2024) (“AI Standardisation Guidelines”). The AI Standardisation Guidelines set out a comprehensive AI standards framework covering foundational support, key technologies, smart products and services, and industry applications, offering direction for the adoption of AI in sectors such as education, healthcare, transportation, logistics, and finance. Additionally, in August 2024, the State Council released the Opinions on Improving the Market Access System, emphasising the need to optimise the market environment for emerging fields like AI. In December, the National Intellectual Property Administration introduced the Guidelines for Patent Applications Related to AI (Trial), setting standards for intellectual property applications in new sectors and business models, including AI.

Local governments have also actively responded by introducing AI development policies. For instance, Beijing’s Implementation Plan for Computing Infrastructure Development (2024–2027) aims to enhance computing infrastructure to support AI innovation and application. Guangdong Province released the Measures for Empowering Industries with AI, promoting the widespread adoption of AI across sectors. Zhejiang Province published the “AI+” Action Plan (2024–2027) (Draft for Comment), outlining specific measures for deep AI integration into various fields. Meanwhile, Shenzhen introduced the Measures to Build a Pioneer City for AI, focusing on establishing itself as one of the leading cities in AI innovation and application. These policies reflect a strong commitment at all levels of government to advancing AI adoption, accelerating industrial upgrades, and achieving high-quality development. Through policy guidance and support, local governments are fostering environments conducive to AI growth, driving economic and societal progress.

3) Advancing AI governance through international collaboration

AI is seeking broader international collaboration to address global challenges and opportunities in safety and governance. In September 2024, the TC260 released version 1.0 of the AI Security Governance Framework. This framework aims to foster consensus among governments, international organisations, businesses, and research institutions, encouraging global cooperation to tackle issues such as AI model algorithms, data security, and system security. China has also taken an active role in international standardisation efforts, advancing proposals under ISO/IEC JTC1/SC27 for cybersecurity standards. These initiatives have facilitated knowledge exchange and collaboration between domestic and international stakeholders in areas such as AI security, IoT security, and personal data protection. 

These efforts not only enhance the security and reliability of AI technologies worldwide but also provide a valuable platform for international cooperation in addressing AI-related challenges and opportunities. Through such initiatives, China highlights its proactive role in global AI governance, contributing to collective progress in AI security governance on the international stage.

2. Enforcement developments

1) The initial infringement cases have surfaced in various areas of AI applications

The rapid development of AI has driven innovation across various industries, but it has also introduced new legal challenges. In 2024, several landmark AI-related infringement cases were heard in Chinese courts. In February, the Guangzhou Internet Court issued the ruling on copyright infringement by a generative AI service provider, determining that AI image-generation platforms must take measures to prevent producing images that are substantially similar to copyrighted works, and that the platform, as an AI service provider, must fulfil a duty of reasonable care. This marked China’s preliminary judicial response to whether AI-generated content constitutes infringement. In April, the Beijing Internet Court ruled in China’s first case involving the infringement of personality rights related to AI-generated voices, affirming that the voice rights of natural persons could extend to AI-generated voices, provided they are recognisable. Later, the court also heard the first case involving copyright infringement in the training of AI painting models. These cases are expected to provide valuable guidance for future legislative practices and underscore the growing challenge of balancing the compliant use of AI technology with the protection of traditional rights, a key issue for regulators to address.

2) Filing of LLMs and deep synthesis algorithms in full swing

In 2024, the filing of LLMs and deep synthesis algorithms continued to progress. From one viewpoint, the Cyberspace Administration and relevant bodies have been carrying out the filing of generative AI services in line with the Generative AI Measures. By 31 December 2024, over 300 generative AI services had been registered. Conversely, since January 2024, the CAC has published seven batches of filing announcements for deep synthesis service algorithms, completing the filing of thousands of algorithms. Compared to the first year of filing in 2023, the 2024 results reflect greater efficiency and standardised management, laying a stronger regulatory foundation for the ongoing development of LLMs and deep synthesis algorithms. 

3. Outlook for 2025

In 2025, with the deeper application of AI and the increasing complexity of compliance scenarios, we expect China to continue strengthening its regulatory framework. (We will publish a series of articles comparing Chinese AI-related legislation with European AI legislation. If you would like to be posted, please follow us through the contact information at the bottom of this article.)

1) Draft of the AI Law may be released

On 6 June 2023, the State Council’s 2023 Legislative Work Plan was released, confirming the inclusion of the AI Law on the agenda. In May 2024, the State Council’s 2024 Legislative Work Plan again listed the draft of the AI Law as a pending item for review. This reflects the lawmakers’ careful consideration of the draft and highlights the increasing complexity and urgency of the issue. In 2025, we remain hopeful for the release of the draft, which will mark a significant milestone in China’s progress in AI governance.

2) A series of standard regulations will be introduced

According to the AI Standardisation Guidelines, the MIIT, the CAC, and other relevant departments aim to improve the integration of AI industry standards with technological innovation by 2026. Over 50 new national and industry standards are expected to be formulated, accelerating the formation of a high-quality development framework for the AI industry. Therefore, we anticipate the introduction of more AI governance standards and regulations in 2025, further streamlining research and application in the AI sector.

Part II: Empowering the Telecommunications Industry

In 2024, China made significant progress in the openness and regulation of its telecommunications sector. Value-added telecommunication services were further opened to foreign investment, with foreign companies now able to independently operate IDC, CDN, and other services in several regions. Several cities launched pilot projects for d0mestic Virtual Private Network (“IP-VPN”) business expansion, attracting overseas capital and technology into the market. At the same time, basic telecommunication services are moving towards high-quality development, with initiatives such as IPv6 deployment and the commercialisation of 5G lightweight technologies accelerating, and telecommunication infrastructure continuously improving. In terms of enforcement, telecom scams became a key focus, with multiple departments releasing typical cases and intensifying efforts to combat cross-border crime. Supervision of radio equipment and management of applications (“Apps”) and communication security also progressed, creating a safer and more compliant development environment for the sector. Overall, in 2024, the combined efforts in regulation and enforcement have fostered openness and high-quality growth in the telecommunications industry.

1. Regulatory developments

1) Orderly expansion of foreign access to value-added telecommunication services

In 2024, the further opening-up of value-added telecommunication services emerged as a key highlight. In April, the MIIT issued a notice regarding the pilot expansion of foreign access to value-added telecommunication services, announcing plans to assess and evaluate eligible regions for the initiative. In October, the pilot projects officially began, allowing foreign enterprises to wholly own businesses such as IDC and CDN in pilot zones in Beijing, Shanghai, Hainan, and Shenzhen. Additionally, in July, the State Council approved pilot projects in Shenyang, Nanjing, Hangzhou, Guangzhou, and Chengdu, permitting foreign investment in IP-VPN services with a shareholding limit of 50%, encouraging overseas telecommunication operators to enter the Chinese market through joint ventures and injecting new vitality into the industry.

2) Basic telecommunication services moving towards high-quality development

In 2024, the focus in the basic telecommunication sector shifted towards high-quality development. For example, the MIIT released typical cases of telecommunication infrastructure co-construction and sharing, as well as quarterly service quality reports, further clarifying the requirements for telecom infrastructure and services. At the same time, MIIT, in collaboration with other departments, issued the 2024 Work Plan for Advancing the Large-Scale Deployment and Application of IPv6, launching a special project on “Network De-NAT” to promote IPv6 deployment and usage. Additionally, MIIT initiated the 2024 5G Lightweight (RedCap) integration action to accelerate the commercial rollout of 5G RedCap. These measures are laying the foundation for the development and optimisation of basic telecom networks while providing strong support for improving telecommunication services and enhancing efficiency.

2. Enforcement developments

1) Cross-border telecom scams become a focus of enforcement activities

In terms of enforcement, efforts to combat cross-border telecom scams were significantly strengthened in 2024. In February, the Supreme People’s Court (“SPC”) released typical cases related to cross-border telecom network scams and associated crimes. In July, the Supreme People’s Procuratorate (“SPP”) published ten major cases of cracking down on cross-border telecom network scams and related crimes. At the same time, the SPC, SPP, and the Ministry of Public Security (“MPS”) jointly clarified the legal standards for handling criminal cases related to cross-border telecom network scams. In December, the SPP and the MPS jointly supervised the fourth batch of major cross-border telecom network scam cases. These actions highlight China’s determination to combat cross-border telecom scams in 2024, while also offering valuable insights and experiences for other countries.

2) Radio, Apps and communication security remain key regulatory focuses

Radio management, Apps filing, and communication security remain key areas of regulation. In January, the MIIT issued the revised Measures for the Management of Amateur Radio Stations, refining the policies on radio station, call sign management, and operational technical competence, etc. In May, MIIT published the Measures for the Supervision and Inspection of Radio Transmitting Equipment, which mandates “dual random, one public” checks on existing radio transmission equipment and standardises administrative enforcement actions during the inspection process. At the same time, the CAC released the second batch of filling numbers for App distribution platforms, enhancing the management of these platforms. Local telecommunications regulators accelerated the removal and shutdown of unfiled Apps, further standardising market order. In terms of communication security, in May, the SAMR implemented quality supervision and random inspections for 147 types of products, including servers and laptops. In September, MIIT released the Regulations on the Safety Production Management of Communication Construction Projects (Draft for Comments), aimed at strengthening safety production in telecommunications construction. Overall, enforcement actions related to radio, Apps, and communication security focus on regulating market order and ensuring industry safety.

3. Outlook for 2025

In 2025, we anticipate further breakthroughs in the telecommunications sector, particularly in market openness and service quality. From one angle, the gradual maturation of the value-added telecommunication business pilot projects and the further relaxation of market entry barriers will bring more innovative opportunities, a wider market, and a broader range of services, driving the industry towards greater standardisation, professionalism, and internationalisation. From a different angle, with the MIIT’s “Broadband Frontier” initiative and various measures promoting key technological innovations like 5G-A and 6G, the telecommunications industry will better empower the real economy and contribute to high-quality economic development. Additionally, we expect that regulatory and enforcement efforts in specific areas, such as radio management and communication security, which concern significant national and public interests, will remain stringent. Therefore, businesses in the industry should closely follow regulatory trends to ensure ongoing compliance.

Part III: The NEV and ICV Industry

In 2024, the government promoted the adoption and application of NEVs and ICVs through a series of infrastructure development measures and industry support policies. For example, planning the layout of charging and battery-swapping facilities and allocating dedicated Internet of Vehicles (“IoV”) numbers further boosted the sector’s innovation and market competitiveness. In terms of safety, the regulatory focus in the NEV sector remained on battery safety and recycling, while enforcement efforts in the ICV sector concentrated on pilot projects and the safe application testing of autonomous driving technologies. Overall, the NEV and ICV industries continued to thrive under strong policy guidance and regulatory support in 2024.

1. Regulatory developments

Infrastructure development and policy support boost the growth of NEVs and ICVs

Regulatory authorities are steadily advancing the high-quality development of the NEV and ICV industries. In the NEV sector, in April, the Ministry of Finance, the MIIT, and the Ministry of Transport jointly issued a notice on the Pilot Work for Expanding Charging and Battery-swapping Facilities in Rural Areas, aiming to improve public charging infrastructure and boost NEV consumption in rural counties and surrounding areas. In June, the MIIT sought public feedback on two drafts: the Safety Requirements for Electric Vehicle Conductive Charging Systems and the Announcement on Battery Replacement for New Energy City Bus Vehicles, in order to ensure safe travel for NEVs.

In the field of ICVs, in May, the MIIT announced a plan to issue 100 million dedicated IoV numbers to support the high-quality development of ICVs and the IoV. In August, the MIIT sought public feedback on the Notice on Further Strengthening the Access, Recall, and Software Online Upgrade Management of ICVs (draft for comments). At the same time, the first batch of mandatory national standards for China’s ICV sector were officially introduced: Technical requirements for vehicle cybersecurity (GB 44495-2024), General technical requirements for software update of vehicles (GB 44496-2024), and ICVs – Data Storage System for Automated Driving (GB 44497-2024), laying the foundation for the industry’s regulatory development and safety. Additionally, policies from regions such as Beijing, Zhejiang, and Chongqing have been released to further strengthen the development of industry clusters and technological innovation in the ICV sector.

2. Enforcement developments

1) NEVs: Focusing on battery utilisation and safety regulation

The utilisation of batteries in NEVs and safety regulation have received increased attention. In August, the industry’s first safety warning model evaluation standard for power batteries, Evaluation Methods for Electric Vehicle Battery System Safety Warning Models (T/CAAMTB 199-2024), was officially approved and implemented on 1 September 2024. This standard aims to standardise the evaluation process of safety warning models for NEV battery systems, with a focus on enhancing the safety and reliability of these vehicles. In December, the SAMR announced that compulsory product certification (CCC certification) would be implemented for power supply equipment of NEVs. Meanwhile, the MIIT revised and released the Industry Standards for the Comprehensive Utilisation of Waste Power Batteries from NEVs (2024), to promote the utilisation of used batteries and encourage high-quality development within the industry.

2) ICVs: pilot projects expanding, safety of autonomous driving technology remains a key regulatory focus

In January 2024, the MIIT and four other departments jointly issued the Notice on Launching Pilot Applications for Integrated Vehicle-Road-Cloud Systems in ICVs. The notice focused on promoting the coordinated development of vehicle-road-cloud integration and aimed to establish a series of city-level pilot projects with consistent architecture, unified standards, interoperable services, and secure reliability. In July, the five departments officially launched the “Vehicle-Road-Cloud Integration” pilot applications, covering 20 cities, including Beijing and Shanghai. In April, the Ministry of Transport also released the second batch of pilot projects for intelligent transportation (focusing on autonomous driving and smart construction), which span various scenarios, including urban mobility, freight logistics, and industrial mining areas. In June, MIIT, the MPS, and other departments-initiated pilots for the access and road testing of ICVs, as per the Notice on Launching Pilot Work for ICVs Access and Road Testing. By the end of December, the regulations for promoting ICVs in Hefei, Wuhan, and Beijing were officially passed, offering a potential reference for further regional legislation. These initiatives are designed to advance the application and development of ICV technologies, enhancing the intelligence and safety of transportation systems.

3. Outlook for 2025

In 2025, the recycling and regeneration of used batteries, along with the electrical safety control of batteries, will likely remain a top priority for regulation in the NEV sector. Notably, the new annual inspection regulation for NEVs, Code of practice for NEVs safety operation inspection (GB/T 44500-2024), will take effect on 1 March 2025, with a focus on strengthening inspection standards for batteries and electrical systems to ensure vehicle safety and sustainability. 

In the area of ICVs, with specific regulations being introduced in cities like Hefei, Wuhan, and Beijing, we expect more local governments to follow suit and refine their legislative initiatives for ICVs. These regulatory and legislative efforts will not only improve the overall standards of the industry but also lay a strong foundation for its future development.

If you’d like to speak with us about how to align your business, or subscribe for our newsletters and be notified of our events on China TMT regulatory updates, please contact James Gong at [email protected].