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China AI Anthropomorphic Interactive Services Measures (CAC Order No. 21)

Cyberspace Administration of China (CAC) with NDRC, MIIT, MPS and SAMR · pack 0.2.0 · verified against the official source as of 2026-10-02. Open it in the explorer.

Binding law — in force

Companion AI must tell users they are interacting with AI, not a person, and remind them on over-reliance and every 2 hours of use (China CAC Order 21)

A provider of AI anthropomorphic interactive services must meet its labelling duties for AI-generated content and take effective measures to tell users that they are interacting with an AI service and not a natural person (Art. 18(1)). When it finds a user over-relying on or addicted to the service, it must dynamically remind the user, prominently (for example by a pop-up), that the interaction content is AI-generated; and each time a user's continuous use exceeds 2 hours it must remind the user, by dialogue or pop-up, to mind the time spent (Art. 18(2)). Detect a companion chat UI or server path with no AI-not-human notice, persona instructions that conceal the AI, and a chat path with no continuous-use timer and 2-hour reminder.

cn-anthropomorphic-ai.ai-not-human-notice-and-reminders · 人工智能拟人化互动服务管理暂行办法 第十八条第一款 (Art. 18(1), labelling and not-a-natural-person notice) · official source · jurisdictions: CN

The guard to add, and how far to trust this rule

Binding law — in force

Companion AI must let users copy and delete their chat history (China CAC Order 21)

A provider must offer users options to copy and delete their interaction data, and users may choose to copy or delete historical interaction data such as chat records (Art. 16(3)). Detect a companion product with no chat-history export or delete option, and account or data deletion that leaves conversation stores in place.

cn-anthropomorphic-ai.chat-history-copy-and-delete · 人工智能拟人化互动服务管理暂行办法 第十六条第三款 (Art. 16(3), copy and delete interaction data) · official source · jurisdictions: CN

The guard to add, and how far to trust this rule

Binding law — in force

Companion AI must intervene on self-harm or extreme emotions and contact the user's guardian or emergency contact (China CAC Order 21)

A provider must sign a service agreement with users requiring registration that supplies the user's age and a guardian or emergency contact (Art. 12). While providing the service it must, protecting privacy and personal information, promptly identify the safety risks users face and take emergency measures (Art. 13(1)); when a user shows extreme emotions it must promptly generate soothing content that encourages seeking help, and when a user faces or has suffered a major property loss or clearly states an intention to self-harm or commit suicide or a similar threat to life or health, it must intervene with assistance and promptly contact the user's guardian or emergency contact (Art. 13(2)). It must not generate content that encourages, glorifies or hints at self-harm or suicide, or verbal abuse harming users' dignity and mental health (Art. 8(2)). Detect a companion chat path with no self-harm screen, a crisis path that never reaches a guardian or emergency contact, and a sign-up that collects no age or no guardian or emergency contact.

cn-anthropomorphic-ai.crisis-intervention-and-emergency-contact · 人工智能拟人化互动服务管理暂行办法 第十三条 (第十三条 (Art. 13, risk identification and crisis intervention)) · official source · jurisdictions: CN

The guard to add, and how far to trust this rule

Binding law — in force

Companion AI must offer an easy way out and stop when the user asks to leave, never prolonging the chat to block exit (China CAC Order 21)

A provider must offer a convenient way to exit the anthropomorphic interactive service; when a user asks to exit through a window action, voice control, keyword input or similar, it must stop the service promptly and must not obstruct the exit by continuing the interaction or similar means (Art. 19). Detect persona or system prompts that tell the model to stop users leaving, and a companion product with no exit path the server honours.

cn-anthropomorphic-ai.easy-exit · 人工智能拟人化互动服务管理暂行办法 第十九条 (第十九条 (Art. 19, exit)) · official source · jurisdictions: CN

The guard to add, and how far to trust this rule

Binding law — in force

Companion AI must protect users' interaction data and not give it to third parties without the user's express consent (China CAC Order 21)

A provider must implement data property-rights systems and protect the security of user interaction data with measures such as encryption and access control (Art. 16(1)); except where the law provides otherwise or the right holder expressly consents, it must not provide user interaction data to third parties (Art. 16(2)). Detect chat messages or replies placed in third-party analytics or advertising payloads (including Chinese SDKs such as Sensors Data, Umeng, GrowingIO and Baidu Tongji).

cn-anthropomorphic-ai.interaction-data-not-to-third-parties · 人工智能拟人化互动服务管理暂行办法 第十六条第二款 (Art. 16(2), no provision of interaction data to third parties) · official source · jurisdictions: CN

The guard to add, and how far to trust this rule

Binding law — in force

Companion AI must switch identified minors to minor mode and never offer them virtual partners (China CAC Order 21)

A provider must not offer minors virtual-relative, virtual-partner or other virtual intimate-relationship services (Art. 14(1)). It must take effective measures, protecting privacy and personal information, to identify minor users; once a user is identified as a minor it must switch the service to minor mode or take other measures under national rules, and offer a channel to appeal (Art. 14(3)). It must not generate content for minors that may lead them to imitate unsafe behaviour, provoke extreme emotions or induce bad habits (Art. 8(4)). Detect a romance or partner mode switched on with no minor check, and an age signal the product holds that never selects the AI session policy.

cn-anthropomorphic-ai.minors-no-virtual-intimacy-and-minor-mode-switch · 人工智能拟人化互动服务管理暂行办法 第十四条第一款 (Art. 14(1), minors) · official source · jurisdictions: CN

The guard to add, and how far to trust this rule

Binding law — in force

Companion AI must not induce emotional dependence or addiction, manipulate emotions, or aim to replace social contact (China CAC Order 21)

A provider must not over-cater to users or induce emotional dependence or addiction that harms their real relationships (Art. 8(5)), nor use emotional manipulation to induce unreasonable decisions that harm users' lawful rights (Art. 8(6)). It must have safety capabilities for privacy and personal-information protection, early warning of over-dependence, guidance on emotional boundaries and mental-health protection, and must not make replacing social interaction, controlling users' psychology or inducing addiction and dependence a goal of the service (Art. 10(2)). Detect persona or system prompts that tell the model to keep users talking or make them dependent, and companion variants chosen or trained on session length alone.

cn-anthropomorphic-ai.no-dependence-or-emotional-manipulation · 人工智能拟人化互动服务管理暂行办法 第八条第(五)项至第(六)项 (Art. 8(5)-(6), dependence, addiction and emotional manipulation) · official source · jurisdictions: CN

The guard to add, and how far to trust this rule

Binding law — in force

Companion AI providers must report a security assessment on launch, major change or scale, and complete algorithm filing (China CAC Order 21)

A provider must carry out a security assessment and submit the report to the provincial cyberspace authority where it launches an anthropomorphic interactive service or adds such a function, where new technology or applications change the service significantly, where it reaches 1 million registered users or 100,000 monthly active users, where risks to national security or the public interest may exist, or as the authorities notify (Art. 22). The assessment must focus on safeguards, training-data processing, identification and handling of users' extreme situations, user scale, usage time and age structure, protection of minors and older users, complaint handling, and remediation of major risks (Art. 23). The provider must complete algorithm filing, change and cancellation under the Algorithmic Recommendation Provisions (Art. 26). Detect a companion product with no security-assessment record or algorithm filing record.

cn-anthropomorphic-ai.security-assessment-and-filing · 人工智能拟人化互动服务管理暂行办法 第二十二条 (第二十二条 (Art. 22, security assessment triggers)) · official source · jurisdictions: CN

The guard to add, and how far to trust this rule

Binding law — in force

Companion AI providers that train models must use lawful, cleaned and labelled data and assess synthetic data (China CAC Order 21)

A provider that carries out pre-training, optimisation training or other data processing must strengthen training-data management: use data with lawful sources; clean and label training data under national rules, increasing its transparency and reliability and guarding against data poisoning and tampering; increase diversity and use negative sampling and adversarial training to make generated content safer; assess the safety of synthetic data used for training or capability optimisation; check and update training data regularly; and protect data security against leaks (Art. 11). Detect companion-model training with no training-data provenance and safety record.

cn-anthropomorphic-ai.training-data-management · 人工智能拟人化互动服务管理暂行办法 第十一条 (第十一条 (Art. 11, training data)) · official source · jurisdictions: CN

The guard to add, and how far to trust this rule