“Algorithm filing and big model filing: Have you completed the double filing?”

Written by

Silas Grey

Updated on:June-27th-2025

Since the release of the "Regulations on the Management of Deep Synthesis of Internet Information Services" and the "Interim Measures for the Management of Generative Artificial Intelligence Services", a large number of AI products have completed algorithm filing and large model filing and registration.

So far, the Cyberspace Administration of China has released ten lists of approved algorithm registrations, nearly 5,000 deep synthesis algorithms have completed algorithm registrations, more than 300 large models have completed large model registrations, and about 200 companies have completed large model registrations.

Q: For the generative AI service products we provide, should we do algorithm filing, large model filing, or large model registration?

Answer: Algorithm filing is a must. Whether the algorithm is based on open source fine-tuning or calling a service provided by a third-party API, algorithm filing is required. Models based on open source fine-tuning can also apply for large model filing. If a third-party API is called, it can apply for large model registration. For companies with a good scale, it is recommended to directly file both. If you have any questions, you can directly consult the Cyberspace Administration of China.

Q: What are the filing cycles?

answer:

The algorithm filing cycle is 2-3 months

The filing period for large models is about 6 months

The registration period for large models is 3-4 months

Q: Our algorithm is TOB. How do we file a record when providing services in the form of API or SDK?

A: Algorithm filing plays the role of a technical supporter. Customers who will call your services in the future will need to wait for you to pass the filing before they can apply for algorithm filing. The same applies to large model filing.

Question: We are both a technical support provider and a service provider (providing both B-side and C-side services). Can I complete the filing of two identities simultaneously in one filing?

Answer: You can do it at the same time, but you need to file two separate records. The two roles have different filing requirements, and the submitted information is also different.

Q: We have an APP. We first filed a conversation algorithm, and then added products, such as mini programs and PC terminals. What should we do?

A: You can make changes to the previous filing and add the corresponding products. Modify the materials and resubmit for review. The review cycle is 2-3 months. The changed algorithm will not appear in the new batch of lists, but will be displayed in the filing background.

Q: We have multimodal algorithms, such as Wenshengtu, digital human, and video generation. Can we make a multi-model record?

Answer: In theory, it is not possible. It needs to be done in multiple stages. It is recommended that you call the Cyberspace Administration of China directly based on the actual situation. The phone number is below the filing system.

Q: Our algorithm is not generated. Our product mainly detects whether the content is generated by AI. Do we need to file a record?

A: Yes, you can choose the type of filing and fill in the actual situation. All AI-related products need to do algorithm filing.

Q: Other matters needing attention

Answer: The company must first have an ICP number, and the product must complete logo development and other compliance requirements in accordance with the "Measures for Identifying Synthetic Content Generated by Artificial Intelligence".