China AI policy

Automakers can apply for the second batch of the L3 access pilot to obtain conditional approval

M- and N-category vehicles with L3/L4 autonomous systems must comply with the mandatory standard before 1 July 2027 or cannot be sold.

Mountain scenic areas in Shandong present procurement and deployment opportunities for hiking-assist robot vendors

Transfers of AI technology, models or related technical materials abroad (including to ASEAN) will require prior export licences, raising deal timelines and compliance costs

Automakers and ADAS suppliers must audit all marketing materials, manuals, and launch statements to remove exaggerated claims or wording that downplays driver responsibility

Cross-border export or transfer of AI, biopharma or solar technology will require approval, so companies must plan licensing ahead

Overseas localised deployment of restricted large models falls under export control and requires a licence (automatic licence available for deployment on overseas self-owned cloud); API calls, SaaS apps and lightweight on-device deployment are outside scope.

Foreign AI services must obtain Chinese AI approval before launching in China; Apple's approval provides a reference path for similar products.

Licensed banks operating in Hong Kong must establish clear accountability mechanisms and ownership for AI systems under the ART framework

Companies doing AI R&D or deployment in Hong Kong can expect greater local compute supply; watch for application channels and pricing of compute resources.

On-device LLMs offered in China must complete CAC filing before launch; devices without updated filings (e.g. iPhone 15/15 Plus) do not carry the AI features

Mobile phone manufacturers must file AI models used in their devices with Chinese regulators

Clarifies AI's position as a teaching auxiliary tool rather than a teacher replacement

All teachers nationwide must participate in full-coverage AI literacy training, involving adjustments to teacher qualification exams and certification content.

Companies need to align their business strategies with Hong Kong's AI development direction

Clear liability rules established for accidents involving autonomous vehicles

Companies must ensure AI applications comply with new regulations, avoiding excessive usage

AI-generated marketing content using real people's likeness or voice is a primary enforcement target, risking account bans and content removal

Research institutions need to increase AI R&D investment, particularly in foundation models and intelligent scientist systems

Operators can formally apply for commercial autonomous vehicle operations, moving beyond pilot programs

Companies must strengthen core technology R&D in multi-sensor fusion, algorithms, solid-state batteries, automotive chips, and operating systems

Chinese AI companies must ensure compliant handling of user data and prevent unauthorized data transfers

Hong Kong companies will have opportunities to participate in AI research and industry collaboration projects with Austria

AI elevated to strategic priority level, indicating future policy support and funding

Mobile on-device AI service providers must complete registration to operate in China

Manufacturing enterprises are required to accelerate the application of AI in R&D design, production manufacturing, and management operations to enhance digitalization and intelligentization, aligning with national industrial policy directions.

Obligations: Companies using Zhipu MaaS must apply for and enable the non-storage feature if they require strict data privacy protection for user interactions. Compliance is required for user requests.

E-commerce and livestream platforms must adopt AI technology to strengthen compliance and prevent issues like counterfeit products and price fraud

Companies must strengthen AI-manufacturing integration, developing smart factories and intelligent manufacturing solutions

Obligations: Companies must comply with new evaluation standards for token factories, focusing on core technical metrics like model adaptation capacity and energy efficiency. • Opportunities: Firms with leading token factories can receive government support. Companies involved in model technology iteration, chip adaptation, and overseas service development can tap into new market opportunities. • Deadlines: The plan is set for implementation from 2026 to 2028, with specific milestones for building factories, launching platforms, and achieving technology breakthroughs.