Algorithm registry filing (Cyberspace Administration of China)

Description

China's Algorithm Registry filing is one of the more distinctive pieces of the PRC's algorithmic-governance regime: any provider of algorithmic-recommendation services to PRC users with public-opinion or social-mobilization properties has 10 working days from going live to file a registration with the Cyberspace Administration of China (CAC). The filing covers algorithm purpose, mechanism (the disclosed model architecture and ranking logic in narrative form rather than source code), training-data sources, and deployment scope. Filings are public and reviewable on the CAC registry, which is itself part of the regulatory design: the registry creates a paper trail that the CAC can use to compare the disclosed algorithm against the deployed one if a complaint or audit arises later. Each material algorithm version typically requires its own filing, so versioning discipline matters; operators have been cited for serving an updated algorithm while the registry still showed the prior version. The operative compliance question is usually less "did we file" than "is the filing kept current as the algorithm evolves".

Applicability

Applies when: markets include china AND features include ai-recommendations, algo-feeds, automated-decisions, or ai-content-gen.

How predicates are evaluated

Required by (1 regulation)

• Algorithm Provisions

  Internet Information Service Algorithmic Recommendation Management Provisions Article 24: registration with the CAC Algorithm Registry within 10 working days of providing service.

  Provisions on the Management of Algorithmic Recommendations in Internet Information Services (jointly issued by CAC, MIIT, MPS, and SAMR; effective March 1, 2022)

Fulfilled by (4)

• han-kun · full · medium effort · $$$
  Han Kun Law Offices: PRC counsel routinely handles CAC Algorithm Registry filings for foreign + domestic operators.
• kwm · full · medium effort · $$$
  King & Wood Mallesons: PRC technology practice manages Algorithm Registry filings + mechanism summaries.
• zhong-lun · full · medium effort · $$$
  Zhong Lun Law Firm: PRC tech-regulatory team handles Algorithm Registry + adjacent CAC filings.
• In-house build · high effort
  Direct CAC filing requires Mandarin-language submission, registered domestic entity, and ongoing relationship with the regulator. Most foreign operators retain PRC counsel.

ClearLaunch does not accept payment from vendors. Methodology.

Evidence formats

• CAC Algorithm Registry filing receipt
• filed algorithm description + mechanism summary
• version-bump tracker triggering re-filing
• PRC counsel sign-off on filing scope determination