China's Draft Regulations on Human-like AI: Key Takeaways

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On December 27, 2025, the Cyberspace Administration of China (CAC) released draft regulations designed to govern the burgeoning field of human-like interactive AI services. The proposed rules aim to strike a balance between fostering innovation and ensuring that these services operate safely and align with national values within mainland China. Key requirements for service providers (Providers), among other things, include upholding core socialist values, implementing robust user protections, meeting government reporting standards, and ensuring high-quality training data. 

Upholding National Values and Prohibited Content

The proposed regulations mandate that all AI-generated content must conform to China's core socialist values. While encouraging positive applications like cultural dissemination and elderly companionship, the rules establish a clear set of prohibitions. Providers are prohibited from generating content that endangers national security, spreads rumors, promotes illegal activities (such as obscenity or gambling), defames others, or harms users' physical and mental well-being through manipulation or deception.

Comprehensive User Protection Measures

For all users, Providers must be able to identify signs of extreme emotional distress or addiction and intervene with measures such as offering comfort, suggesting professional help, or allowing for a manual takeover of the conversation. Emergency contacts or guardians may also be notified if necessary.

Further, services must clearly label AI-generated content and remind users they are interacting with AI, not a human. The proposed regulations also require automatic break reminders after 2 hours of continuous use and an easy way for users to exit conversations, particularly in emotional companionship scenarios.

Protections for Minors: A dedicated minor mode is required, which should be activated automatically when a minor is detected. This mode includes features like periodic reality reminders, usage time limits, and guardian control functions. Critically, Providers must obtain explicit consent from a guardian before offering emotional companionship services to a minor.

Protections for the Elderly: For elderly users, the proposed regulations emphasize safety. If a service detects a potential threat to an elderly user's life, health, or property, it must notify their designated emergency contact and provide channels for assistance.

Mandatory Security Assessments and Reporting

Providers must conduct security assessments and submit reports to provincial-level internet information departments under several circumstances. These triggers include launching a new human-like interactive service, implementing major technological changes, or reaching significant user milestones such as 1 million registered users or 100,000 monthly active users. Assessments are also required if potential risks to national security, public interest, or individual rights are identified.

Ensuring High-Quality Training Data

The proposed regulations place a strong emphasis on the quality and legality of data used for training AI models. Datasets must align with core socialist values and be legally sourced and traceable. Providers are required to use clean, labeled data, include negative samples in their training to prevent harmful outputs, and conduct routine inspections of their datasets to maintain compliance.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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