Section · Regulation & PolicyIndependent · Published in Germany

How China governs AI — and where it meets Europe’s rules

China regulates AI earlier, faster and more granularly than almost any jurisdiction, but with the opposite philosophy to the EU AI Act: targeted rules per technology wave instead of one framework. We explain both rulebooks and the places they collide.

3 analyses · 4 core Chinese rules since 2022

The rulebook

Four rules, each answering one technology wave.

2022

Algorithm Recommendation Provisions

The foundation: recommendation algorithms must be registered with the regulator, and users can opt out of personalisation.

2023

Deep Synthesis Provisions

Rules for deepfakes and synthetic media, with consent and labelling duties.

2023

Interim Measures for Generative AI

The core rulebook for chatbots and generative models: security assessment before launch, moderation duties, data-quality requirements.

2025

AI Content Labelling Rules

Mandatory visible and embedded labels for AI-generated content across Chinese platforms.

Who regulates

CAC — Cyberspace Administration of ChinaLeads on content and public-facing services: the algorithm registry and approval of model launchesRegulator→
MIITIndustrial policy and the chip supply chainMinistry→
MOSTResearch strategy and ethics frameworksMinistry→

Two rulebooks

China and the EU, regulating AI side by side

Beijing writes targeted rules, one technology wave at a time. Brussels wrote one framework and phases it in. Dates are when rules take effect.

Date
China
European Union
1 Mar 2022
Algorithm Recommendation ProvisionsRegistration duty; users can opt out of personalisation
10 Jan 2023
Deep Synthesis ProvisionsConsent and labelling for deepfakes and synthetic media
15 Aug 2023
Interim Measures for Generative AISecurity assessment before launch; moderation duties
1 Aug 2024
EU AI Act enters into forceObligations phased in over the following years
2 Feb 2025
AI Act: prohibited practices applyBans on unacceptable-risk systems
2 Aug 2025
AI Act: general-purpose AI rulesDuties for providers of general-purpose models
1 Sep 2025
AI Content Labelling MeasuresVisible and embedded labels on AI-generated content
2 Aug 2026
AI Act: most obligations applyIncluding transparency duties under Article 50
16 Oct 2026
Draft export controls on 23 AI technologiesLicence above 2 trillion parameters; open weights exempted; comments until 15 November

Graphic: Inside China AI · Sources: Cyberspace Administration of China; Ministry of Commerce draft of 16 October 2026; Regulation (EU) 2024/1689 (AI Act).