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, and the structurally interesting piece is that the registry is public. Any provider of algorithmic-recommendation services to PRC users with public-opinion or social-mobilization properties files a registration with the Cyberspace Administration of China (CAC) within a defined window of going live, and the filing then appears on the public CAC algorithm registry where complainants, journalists, and the regulator can compare the disclosed algorithm against the algorithm actually shipping. The filing decomposes into four content blocks. Algorithm purpose names the user-facing problem the algorithm is solving (content ranking, user matching, advertising allocation, news feed assembly). Mechanism describes the model architecture and ranking logic in narrative Mandarin-language form rather than source code; the level of detail expected is enough that a competent reviewer can understand what inputs map to what kind of output, not enough that the operator is handing over training weights or proprietary feature vectors. Training-data sources identify the categories of data the model learned from, with particular attention to whether PRC-resident user data was used and how that data was lawfully collected. Deployment scope describes which services the algorithm runs in and which user populations it reaches. The trade-off pressure on the filing is that operators want the narrative tight enough to be defensible but loose enough that incremental algorithm changes do not constantly trigger re-filing; each material version change re-opens the filing question, and operators have been cited for serving an updated algorithm while the registry still showed the prior version. The statutory anchor is the Internet Information Service Algorithmic Recommendation Management Provisions Article 24, jointly issued by CAC, MIIT, MPS, and SAMR and effective March 1, 2022, which sets the 10-working-day filing window from the date of providing service. The filing is in Mandarin and requires a registered PRC domestic entity, which is why most foreign operators retain PRC counsel (Han Kun Law Offices, King & Wood Mallesons, Zhong Lun Law Firm are the firms most often engaged for this specific filing) rather than attempting direct CAC submission. Evidence formats that satisfy a regulator inquiry include the CAC registry receipt, the filed algorithm-description document, the version-bump tracker that triggers re-filing on material change, and PRC counsel sign-off on filing-scope determination. The operative compliance question across the lifecycle is less "did the operator file" than "is the filing kept current as the algorithm evolves," and that second question is the one the regulator's enforcement record has been built around.

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 (2)

• outside-counsel · full · medium effort · $$$
  PRC counsel routinely handles CAC Algorithm Registry filings and mechanism summaries for foreign and domestic operators. This is a counsel-led regulatory filing, not a product integration.
• 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.

Magist 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