Understanding China’s Algorithm Filing Requirements: A Practical Guide

1. What Is Algorithm Filing?

Algorithm filing, formally called the "Regulations on the Administration of Algorithm Recommendation for Internet Information Services," is a mandatory filing system issued jointly by the Cyberspace Administration of China, the Ministry of Industry and Information Technology, the Ministry of Public Security, and the State Administration for Market Regulation. It aims to regulate algorithm recommendation activities in internet information services and took effect on March 1, 2022.

2. Which Business Scenarios Require Filing?

According to current regulatory requirements, any product or large model that provides algorithm recommendation services to the public in China—i.e., any application that includes algorithm recommendation functions—must complete filing within ten working days from the start of service.

3. Types of Algorithms Covered by Filing

Personalized push algorithms: use user attribute or behavior data for personalized content distribution.

Ranking and selection algorithms: adjust the order of network information based on objective or subjective factors.

Retrieval and filtering algorithms: include both search and filtering mechanisms.

Scheduling decision algorithms: automatically or assistively generate scheduling decisions or provide decision bases.

Generative synthesis algorithms: deep synthesis technologies such as deep learning and virtual reality used to create content.

4. Why Filing Is Necessary

Compliance: operating without approval constitutes illegal business activity.

Fines: violators face penalties ranging from 10,000 to 100,000 RMB.

Liability: criminal or administrative responsibility may be pursued if crimes are involved.

Removal risk: systems, apps, or mini‑programs with algorithm functions may be taken down.

5. Filing Process

The filing consists of two parts—subject filing and algorithm filing—and the entire process typically takes 30–50 working days, extending if the authorities request revisions.

6. Required Materials

Business license.

Algorithm security responsible person’s commitment letter.

Legal representative and responsible person’s ID cards.

Proof of work for the algorithm security responsible person.

Information about the app or website.

ICP filing certificate or ICP operating license.

Algorithm security management documents, self‑assessment report, and proposed public disclosure content.