China TMT: Bi-monthly Update - January and February 2025 Issue

This newsletter summarises the latest developments in Technology, Media, and Telecommunications in China with a focus on the legislative, enforcement and industry developments in this area.

If you would like to subscribe for our newsletters and be notified of our events on China Technology, Media, and Telecommunications, please contact James Gong at [email protected].

Key Highlights

In January and February 2025, relevant regulatory authorities focused on two key areas: artificial intelligence (“AI”) and online information content governance. Through the introduction of regulations, enforcement activities, and other measures, they aim to promote innovation in the AI industry while guiding online platforms and users in fostering a positive online information content ecosystem：

• AI: The National Cybersecurity Standardisation Technical Committee (“TC260”) is accelerating the standardisation of AI applications, guiding enterprises to regulate the labelling of AI-generated synthetic content and establish a key standards system for AI security. The Cyberspace Administration of China (“CAC”), at both national and local levels, has continued to urge enterprises to standardise the provision of generative AI (“AIGC”) and algorithm services through measures such as the publication of filings and registrations for AIGC and launching algorithm governance special actions. Local courts have continued to provide judicial perspectives on the copyrightability of AIGC-generated works. Additionally, the State Council, along with local governments in Suzhou, Wuhan, and Shenzhen, have introduced policies and initiatives to promote the development of the AI industry.
• Online Information Content Governance: The CAC and its Shanghai branch have issued management measures and compliance guidance, requiring multi-channel network (“MCN”) agencies to comply with platform information content governance requirements and regulate the dissemination of military-related information online. Meanwhile, the national Cyberspace Administration has released several summary reports, pointing out that the enforcement focus for 2024 in the field of online information content governance is to vigorously crack down on prominent illegal issues such as cyber violence and malicious traffic promotion. Furthermore, the 2025 enforcement priorities have been further deployed.

In addition to these two key areas, China has made positive progress in other important fields, including basic telecommunications, intelligent connected vehicles, and regulations on “shake-to-open” advertisements in mobile Apps.

Follow the links below to view the official policy documents or public announcements.

Legislative Developments

• TC260 planned to release guidelines on coding rules for relevant service providers, standardising the labelling of AI-generated synthesised content (23 January)

  The TC260 opened the public consultation on the Cybersecurity Standards Practice Guidelines – Coding Rules for Service Providers of AI-Generated Synthetic Content Labelling. The guidelines aim to support the Measures for Labelling AI-Generated Synthetic Content and the national standard Cybersecurity Technology – Labelling Method for AI-Generated Synthetic Content, providing compliance guidance for enterprises on AI-generated synthetic content labelling. The guidelines also provide detailed regulations on coding structure and assignment rules, outlining how providers of AI-generated synthetic content services and content distribution services should conduct implicit metadata labelling activities.

• TC260 planned to release guidelines to enhance the development of AI security standards system (26 January)

  The TC260 opened the public consultation on the AI Security Standards System (V1.0), aiming to support the implementation of the AI Security Governance Framework by systematically organising key standards in the field of AI security. The guidelines categorise the AI security standards system into five key parts: fundamental and general standards, security management, key technologies, testing and evaluation, and products and applications, providing enterprises with clear guidance on effectively preventing and mitigating AI-related security risks.

• TC260 planned to issue guidelines to regulate the display and triggering of “shake-to-open” advertisements in Apps and SDKs (23 January)

  The TC260 opened the public consultation on the Cybersecurity Standards Practice Guidelines –Protecting Personal Rights in “Shake-to-Open” Advertisements, aiming to regulate the display and triggering of “shake-to-open” advertisements in mobile Apps and third-party advertising SDKs. The guidelines explicitly require enterprises to ensure that when offering the “shake-to-open” advertising function through Apps and SDKs, they must meet the following criteria: provide prominent identifiers, clearly explain the consequences of the action, standardise the triggering threshold, and offer convenient options for closing the ad. In addition, the guidelines highlight common issues that infringe on personal rights, such as unclear advertising identifiers, low triggering thresholds, and inconvenient dismissal mechanisms.

• CAC planned to release management regulations to standardise the activities of MCN agencies (10 January)

  The CAC launched the public consultation on the Management Regulations for the Business Activities of MCN Agencies. The regulations aim to standardise the activities of MCN organisations in the field of online information content, fostering a positive online ecosystem. The regulations outline the requirements for online information content service platforms regarding the review, filing, registration, and supervision of MCN agencies. Additionally, the regulations establish specific responsibilities for MCN agencies regarding the management of contracted online accounts, including content review, prohibiting misconduct, and establishing complaint channels, thereby ensuring that online information content activities are conducted in accordance with business ethics.

• CAC and other departments jointly issued management measures to standardise the dissemination of online military information (8 February)

  The CAC issued the Measures for the Management of Dissemination of Online Military Information, aiming to regulate the distribution of military-related content online. The measures establish core obligations for online military information service providers and users concerning account management, content dissemination, and confidentiality. For instance, the measures explicitly prohibit entities from creating, reproducing, publishing, or disseminating content that endangers national sovereignty, security, and territorial integrity, thereby protecting national security and the public interest.

• Beijing SAMR issued three compliance guidelines to guide online trading platform operators in fulfilling their compliance management responsibilities (13 February)

  The Beijing Municipal Administration for Market Regulation (“SAMR”) issued a series of documents targeting online trading platform operators, including the Compliance Guidelines for Service Agreements and Trading Rules, Compliance Guidelines for Information Disclosure and Publicity, and Compliance Guidelines for the Management of Prohibited and Restricted Goods, aimed at regulating online trading market and guiding online platform operators to fulfil their compliance management responsibilities. The Compliance Guidelines for Service Agreements and Trading Rules require platform operators to establish and improve management systems and mechanisms, formulate and implement service agreements and trading rules in accordance with the law, and protect the legal rights and interests of consumers and platform operators. The Compliance Guidelines for Information Disclosure and Publicity stipulates that platform operators should accurately disclose platform service agreements, trading rules, basic public information, and prominent display key information to protect consumers’ right to information. The Compliance Guidelines for the Management of Prohibited and Restricted Goods clarifies that platform operators should establish a list of prohibited and restricted goods, set up management mechanisms, strengthen product posting review and inspections, promptly handle information on prohibited and restricted goods, and actively cooperate with regulatory authorities in enforcement.

• Guangzhou issued regulations to standardise and promote the development of intelligent connected vehicles and their infrastructure, fostering high-quality innovative applications and ensuring safety (20 January)

  Guangzhou issued the Regulations on the Innovative Development of Intelligent Connected Vehicles in Guangzhou, aimed at regulating and promoting the high-quality development of the intelligent connected vehicle industry, driving innovative applications, and enhancing safety guarantees. The regulations require the government to establish guidance and support mechanisms to accelerate the development of the intelligent connected vehicle industry. Additionally, the regulations propose measures such as accelerating infrastructure construction, upgrading communication networks, and advancing mixed traffic pilot zones to vigorously promote the integration of vehicles, roads, and cloud systems, and supporting innovative applications of intelligent connected vehicles.

Enforcement Developments

• CAC reported on 2024 law enforcement actions, cracking down on various online information content violations (25 February)

  The CAC reported on the law enforcement situation for 2024, highlighting the severe crackdown on various online illegal activities. According to the data provided by the CAC, in 2024, the national cyberspace authorities conducted talks with 11,159 websites and platforms, issued warnings or fines to 4,046 websites and platforms, ordered 585 websites to suspend certain functions or information updates, and removed 200 mobile Apps, and disposed of 40 mini-programs. In collaboration with telecom authorities, the regulators revoked licences or registrations for 10,946 illegal websites and shut them down. Additionally, 107,802 accounts were closed in accordance with legal procedures, urging relevant websites and platforms to implement their responsibilities. In terms of addressing online information content, the national cyberspace authorities focused on cracking down on illegal and irregular activities that harm minors’ physical and mental health, online violence, disrupt dissemination order, and damage the online ecosystem. Key issues include platforms failing to meet legal information management obligations, illegal or harmful content on children’s smartwatches that impacts minors, and websites impersonating authoritative news media accounts.

• CAC published information on 2024 AIGC services filing, with 238 new services filed in the year (8 January)

  The CAC released an announcement regarding the filing of AIGC services for 2024. In accordance with the Interim Measures for the Management of Generative AI Services, by 31 December 2024, a total of 302 AIGC services had been registered with the CAC, with 238 new services added in 2024. Additionally, for AIGC applications or functions that directly invoke filed model capabilities via APIs or other methods, 105 such applications or functions were registered with local CACs in 2024.

• CAC released the key focus areas for the 2025 “Clear and Bright” series of special actions, targeting the abuse of AI and other issues (21 February)

  CAC released the key focus areas for the 2025 “Clear and Bright” series of special actions, which aim to address prominent issues, refine specific strategies, and severely crack down on various violations. The CAC has outlined the key tasks for 2025, including tackling problems such as the spread of false information by “self-media” accounts, malicious marketing in the short video sector, the abuse of AI technology, online rumour-mongers in corporate-related activities, the online environment for minors during the summer, and issues related to live streaming tipping.

• CAC released results and typical cases of the “Clear and Bright: 2025 Spring Festival Online Environment Rectification” multi-platform special action, focusing on key issues such as illegal activities for traffic diversion and the infringement of consumer rights (13 February)

  The CAC released the governance results and typical cases of the multi-platform special action, namely, the “Clear and Bright: 2025 Spring Festival Online Environment Rectification.” Targeting six categories of issues—inciting extreme confrontations, fabricating false information, promoting vulgar and obscene content, advocating unhealthy culture, diverting traffic for illegal activities, and infringing on consumer rights—major websites and platforms have effectively fulfilled their primary responsibilities, removed over 1.03 million pieces of illegal and non-compliant information and handled 97,000 accounts. An official from the CAC stated that the vigorous investigation and punishment of accounts, platforms, and MCN agencies that disrupt the online ecosystem will be a key focus of the CACs’ law enforcement efforts moving forward.

• SAMR initiated investigation into a multinational tech giant for alleged violations of the AML (4 February)

  The State Administration for Market Regulation (“SAMR”) issued an announcement stating that it has decided to initiate an investigation into a multinational tech giant for suspected violations of the Anti-Monopoly Law of the People's Republic of China (“AML”). As of now, the SAMR has not released any further details on the progress or results of the investigation.

• Shanghai CAC published information on AIGC service registrations, with 74 registered services (19 February)

  The Shanghai CAC published updated information on AIGC service registrations, with an additional 6 newly registered services, bringing the total to 74. In accordance with the Interim Measures for the Management of Generative AI Services, AIGC services that directly invoke registered models via APIs or other means, and which provide services with public opinion or social mobilisation capabilities within China, must be registered with the relevant cyberspace administrations.

• Shanghai CAC published information on AIGC service filings, with 66 registered services (22 February)

  The Shanghai CAC released the filing information for AIGC services, with 6 newly filed services, bringing the total number of filed services to 66. According to the Interim Measures for the Administration of Generative AI Services, businesses providing AIGC services with public opinion attributes or social mobilisation capabilities are required to complete the filing process with the local cyberspace administration in a timely manner.

• Shanghai CAC and three municipal-level departments launched special action to strengthen the governance of typical issues related to platform algorithms (6 January)

  The Shanghai CAC, in collaboration with three municipal-level departments, launched the special action “Clear and Bright: Pujiang Governance of Typical Algorithm Issues on Online Platforms”. The initiative requires local websites and platforms in Shanghai to conduct self-inspections and corrections regarding key algorithmic violations, such as the “information cocoon” effect and big data-driven “price discrimination”. Currently, many major websites and platforms in Shanghai have actively responded to the call for the special action, issuing announcements regarding the governance of typical algorithm issues on their platforms. They have also provided channels for public complaints and feedback, stating that they will adjust and optimise algorithm applications to promote the use of algorithms in a positive and ethical direction.

• Court of Donghu New Technology Development Zone in Wuhan issued a first-instance judgment, ruling that the copyright of images generated by AIGC belongs to the creator (11 February)

  The Court of Donghu New Technology Development Zone in Wuhan concluded the first-instance trial of a copyright infringement case involving AI-generated images. In this case, the defendant uses images created by the plaintiff through AI software for online promotion without permission. After reviewing the case, the court rules that images generated using AI software fall within the category of “works” and are protected by copyright law. Furthermore, the court determines that the plaintiff’s use of AI software, including adjusting keywords, parameters, styles, and lighting effects, reflects the plaintiff’s personal expression. As a result, the AI-generated images, which exhibit originality, should be considered works in the copyright sense and are thus protected by copyright law. This case provides an important reference for future judicial practice in China regarding the copyrightability of AI-generated content.

Industry Developments

• MIIT granted pilot approval for value-added telecommunication business to 13 foreign-invested enterprises, promoting the expansion of openness in the telecommunication industry (28 February)

The Ministry of Industry and Information Technology (“MIIT”) granted pilot approvals for value-added telecommunications business operations to 13 foreign-invested enterprises located in Beijing, Shanghai, Hainan, and Shenzhen. These enterprises are now permitted to engage in value-added telecommunication services such as Internet access and information services in accordance with the approval conditions. Since the MIIT launched the pilot program to expand the openness of value-added telecommunication services in these four regions in 2024, the investment interest of foreign enterprises in China’s telecommunication market has been further stimulated. As of the end of February 2025, there are more than 2,400 foreign-invested telecommunication enterprises in China, representing a 30% increase compared to the same period in 2024.

• State Council held special action meeting to summarise the achievements of AI development in SOEs and deploy next steps (21 February)

  The State-owned Assets Supervision and Administration Commission of the State Council held a meeting to deepen the deployment of the “AI+” special action for central enterprises. The meeting summarises the progress and achievements made by state-owned central enterprises (“SOEs”) in the development of AI and discusses the key tasks for the future. In recent years, SOEs have made significant progress in key AI areas, such as the implementation of AI in high-value industry application scenarios and the significant improvement of intelligent computing power supply capabilities, thus driving the innovation and development of the AI industry. The meeting emphasises that SOEs should focus on serving national strategies, accelerate the high-quality development of the AI industry, and achieve more landmark achievements and breakthroughs.

• Shanghai CAC and the Municipal Commission of Commerce jointly held a guidance meeting to guide local MCN agencies on complying with content ecosystem regulations (19 February)

  The Shanghai CAC, in collaboration with the Municipal Commission of Commerce, held a classification-based guidance meeting for local MCN agencies, aiming to review the relevant work conducted by the cyberspace authorities in 2024 regarding the management of MCN agencies and to guide businesses in implementing the Shanghai MCN Agency Content Ecosystem Compliance Guidelines (Trial) (“Compliance Guidelines”). The Compliance Guidelines will be implemented in local MCN agencies in Shanghai starting in 2025. They set clear obligations for MCN agencies, focusing on establishing and improving content compliance management systems, strengthening the management of key areas such as account and content security, live streaming, and online protection for minors, as well as actively fulfilling social responsibilities.

• Zhejiang released an action plan to advance the intelligent connected vehicle industry by strengthening supplier-manufacturer collaboration, building an innovation service system, and expanding application scenarios (9 January)

  Zhejiang released the Zhejiang Intelligent Connected Vehicle Industry Development Action Plan (2025–2027), aiming to accelerate the transformation and upgrading of the automative industry and achieving innovative development in intelligent connected vehicles. The action plan highlights enhancing the competitiveness of the intelligent connected vehicle industry as its overall goal, with the aim of achieving rapid development in areas such as the “vehicle-road-cloud integration” application pilot, advanced autonomous driving technology, and the collaborative industry system between manufacturers and suppliers by 2027. The plan outlines key tasks for the future development of the intelligent connected vehicle industry, focusing on five areas: deepening the collaborative industry system, building an innovation service system, strengthening the creation of application scenarios, accelerating infrastructure construction, and advancing breakthroughs in standard systems.

• Suzhou introduced new measures to build a high-level “AI+” innovation development pilot zone (13 February)

  Suzhou released the Several Measures for the High-Level Construction of the “AI+” Innovation Development Pilot Zone, aiming to thoroughly implement the national strategy for developing the next-generation AI and promote the high-quality development of the AI industry. The document outlines 14 specific measures across four key areas: driving high-quality industrial technological innovation, promoting the expansion of high-level application scenarios, strengthening the supply of key elements, and improving the industrial innovation ecosystem. These measures include supporting data technology innovation, encouraging large model innovation applications, and promoting standard formulation, with the goal of building a high-level “AI+” innovation development pilot zone.

• Shenzhen held a press conference announcing plans to establish a ¥10 billion AI and Robotics Industry Fund to support the development of AI enterprises (24 February)

  Shenzhen held a press conference on “building a top-tier innovation and talent development environment”, announcing plans to establish a ¥10 billion AI and Robotics Industry Fund. The fund will focus on AI software, hardware, and embodied intelligence, investing in high-growth enterprises to address financing challenges. The press conference highlights that Shenzhen has already gathered numerous high-quality companies in the fields of large-scale models and robotics, gradually building a complete industry chain ecosystem that spans from foundational technologies to end products. In the future, Shenzhen will increase its investment in the AI and robotics industries, focusing on policies, scenarios, innovation, and robotics to further support the development of AI enterprises.

• Wuhan MEIT planned to issue measures to regulate the management of special funds for AI, ensuring that the funds are used in a standardised, secure, and efficient manner, and promoting the development of the AI industry (24 February)

The Wuhan Municipal Bureau of Economy and Information Technology (“MEIT”) opened the public consultation on the Fund Management Measures for the Relevant Provisions of the “Policies for Promoting the Development of the Artificial Intelligence Industry in Wuhan”, aiming to regulate the management of special funds for AI and to fully leverage the guiding role of fiscal funds. According to the measures, enterprises engaged in services such as computing power, vertical industry model research and development, construction of AI public service platforms, and promotion of AI demonstration application scenarios are eligible to apply for special subsidies under certain conditions, with the goal of promoting the development of the AI industry.