Trains models, in China

Cybersecurity Law of the People's Republic of China (as amended by the Decision of October 28, 2025), Art. 23 · Read the law's page

• This binds a network operator, meaning any organization that owns or manages a network or provides services over one, so it reaches every declared activity and every declared role; the level of protection follows the classification of the network under the classified protection system.
• Formulate internal security management rules and operating procedures, designate a person responsible for network security and put network security protection responsibility into effect (Article 23, item 1).
• Take technical measures against computer viruses, network attacks and network intrusions (Article 23, item 2).
• Monitor and record the network's operating status and security incidents and keep the network logs for not less than six months (Article 23, item 3).
• Take data classification, backup of important data and encryption measures (Article 23, item 4).

Copyright Law of the People's Republic of China (2020 revision), Art. 24 · Read the law's page

• Do not rely on Article 24's closed list of exceptions to justify training an AI model on scraped copyrighted content; none of its items covers text-and-data mining or AI training.
• Treat use of copyrighted material beyond personal study, brief quotation, or the other listed exceptions as needing the rightholder's permission.

Arts. 8 and 13, Provisions on the Management of Network Product Security Vulnerabilities (Ministry of Industry and Information Technology, Cyberspace Administration of China and Ministry of Public Security) · Read the law's page

• Applies to a network operator, meaning the owner or manager of a network or a provider of services over one, so it reaches an app developer that runs its own servers or service (Articles 2 and 8).
• On finding or learning that your network, information system or equipment has a security vulnerability, take measures at once, verify the vulnerability in good time and complete its repair (Article 8).
• Keep a channel for receiving vulnerability information open and unobstructed, and keep the receipt logs for at least 6 months (Article 5).

Data Security Law of the People's Republic of China, Art. 27 · Read the law's page

• This binds any organization or individual engaging in a data-processing activity, regardless of sector, and reaches data generally rather than only personal information.
• Establish and maintain a full-process data-security management system covering the collection, storage, use, processing, transmission, provision, and disclosure of the data you process, and provide data-security education and training to your staff.
• Take the technical measures and other necessary measures appropriate to your processing to keep your data secure.
• Where you process data over the internet or another information network, meet this duty in addition to, not instead of, your classified-protection obligations under the Cybersecurity Law, already this jurisdiction's own deferred network-operator duty.
• If you process important data, an official classification this corpus cannot flag against on its own, designate a person responsible for data security and a managing body, and implement that responsibility.

Data Security Law of the People's Republic of China, Art. 29 · Read the law's page

• Strengthen risk monitoring of your data-processing activity, and on discovering a data-security defect, vulnerability, or other risk, immediately take remedial measures.
• On an actual data-security incident, immediately take disposal measures, promptly notify affected users as provided, and report the incident to the competent authority; the statute states no numeric deadline, only immediacy and promptness.
• This binds the same data processor as this jurisdiction's Data Security Law data-security-program duty; it adds a risk-monitoring and incident-response duty rather than reaching a different party.
• A processor of important data carries an additional, periodic risk-assessment-and-reporting duty under Article 30 tied to the important-data classification rather than to any activity in this vocabulary, so it is not flagged as its own instrument.

Personal Information Protection Law of the People's Republic of China, Arts. 13(6), 27 · Read the law's page

• Confine processing of personal information someone has already made public to a reasonable scope tied to your stated purpose.
• Stop processing an individual's already-public personal information once they expressly decline, even though no prior consent was required.
• Obtain separate consent before any use of already-public personal information that would have a significant impact on the individual, including most AI-training uses.

Interim Measures for the Management of Generative AI Services (生成式人工智能服务管理暂行办法), 2023, Arts. 7-8 · Read the law's page

• Use data and base models from lawful sources when you pre-train or fine-tune a generative AI service offered to the public in China.
• Do not infringe others' intellectual property rights in the training data you use.
• Obtain the individual's consent, or meet another circumstance that a law or administrative regulation sets, before using personal information in training data.
• Take effective measures to raise the quality of your training data and to strengthen its truthfulness, accuracy, objectivity and diversity.
• When you label data during development, set clear, specific and operable labeling rules, assess labeling quality, check a sample of the labeled content for accuracy and give labelers the necessary training.

Interim Provisions on Network Anti-Unfair Competition of the People's Republic of China (SAMR Order No. 91), Art. 19 · Read the law's page

• Do not use technical means to unlawfully obtain or use data lawfully held by another business operator where that impedes or disrupts the normal operation of the network products or services the other operator lawfully provides (Art. 19).

Issued by the State Council on 30 September 2024; effective 1 January 2025

• Have a lawful basis before collecting personal information from network sources.
• Do not use unlawfully obtained data to train AI models.
• Do not collect personal data through automated means without consent.
• Meet the impact-assessment and transparency obligations that apply to automated decision-making.
• Keep records of automated processing activities.

Regulation on Network Data Security Management (State Council Order 790), Arts. 9-11 · Read the law's page

• Applies to a network data processor, meaning an individual or organization that decides for itself the purpose and means of processing network data, for processing in China (Articles 2 and 62); because that reaches almost any organization running a system, this instrument flags on every activity and role this corpus can express.
• Protect network data on the basis of classified cybersecurity protection: keep data security management rules in place and use encryption, backup, access control and security authentication (Article 9).
• On finding a security defect, vulnerability or similar risk in a network product or service you provide, take remedial measures at once, tell users as required and report to the competent department; where national security or the public interest is endangered, also report to the competent department within 24 hours (Article 10).
• Keep an emergency plan for network data security incidents; when an incident occurs, start the plan at once, act to stop the harm spreading and remove the hazard, and report to the competent department as provided (Article 11).
• Where an incident harms the lawful rights and interests of individuals or organizations, promptly tell those affected the incident, the risk, the harm and the remedial steps taken, by phone, text message, instant message, email or public announcement, unless a law or administrative regulation allows non-notification (Article 11).

Anti-Unfair Competition Law of the People's Republic of China (as amended 2025), Art. 10 · Read the law's page

• Do not obtain a rightholder's trade secret by theft, bribery, fraud, coercion, electronic intrusion or other improper means (Art. 10, first paragraph, item 1).
• Do not disclose, use or allow others to use a trade secret obtained by those means (Art. 10, first paragraph, item 2).
• Do not obtain, disclose or use a trade secret where you know or ought to know that an employee, former employee or other entity or individual of the rightholder committed an act listed in the first paragraph (Art. 10, third paragraph).

Anti-Unfair Competition Law of the People's Republic of China (as amended 2025), Art. 13 · Read the law's page

• Do not obtain or use data lawfully held by another business operator by fraud, coercion, or by evading or destroying that operator's technical access controls.
• This duty applies whether or not the collected data is later used to train an AI model.
• It has applied in China since October 15, 2025, and no case has yet applied it.

Measures for the Administration of National Cybersecurity Incident Reporting (Cyberspace Administration of China, issued September 11, 2025), Arts. 2, 4, 5, 8, 9, 12, 14 · Read the law's page

• On discovering or becoming aware of a cybersecurity incident affecting your own operations, grade it against China's four-tier National Cybersecurity Incident Classification and Grading Guide (especially major, major, relatively major, ordinary), and report only where you grade it relatively major or above; an ordinary incident carries no report duty under this instrument.
• Where the incident involves critical information infrastructure, report to your sector's protection-work department and to the public security organ within 1 hour of discovering or becoming aware of the incident.
• Where you are a department of a central or state organ, or a directly affiliated unit of one, report to your own department's cyberspace affairs unit within 2 hours of discovering or becoming aware of the incident.for a public body
• Every other network operator must report to the cyberspace administration department of its own province within 4 hours of discovering or becoming aware of the incident.
• Where your industry carries its own reporting rule, also report as your industry's regulator requires, and report a suspected crime to the public security organ promptly.
• Where an organization or individual provides you network-security or system-operation-and-maintenance services under contract, require that provider by contract to promptly report to you any cybersecurity incident it discovers through monitoring, and to assist your own reporting under these Measures; this is the paragraph that reaches a cloud host, managed-security vendor, or AI operator serving you as its customer.
• Within 30 days of completing disposal of a relatively major incident or above, submit a summary report covering the incident's cause, your emergency response, the harm caused, accountability, remediation, and lessons learned, through the same channel you used for the original report.
• This binds a network operator, meaning the owner, manager, or network service provider of a network, that builds or operates a network, or provides a service through a network, inside China; because that reaches almost any organization running a system, this instrument flags on every activity and role this corpus can express rather than a narrower guess.
• A major or especially major incident additionally triggers an escalation between government bodies up to the national cyberspace administration after you report; that further escalation is not a step you perform yourself.
• Taking reasonable and necessary protective measures, disposing of the incident under your emergency plan, effectively reducing its impact and harm, and reporting it promptly as these Measures require can draw lighter treatment, or none at all, of the liability of your unit and its personnel for the incident.

Measures for AI Science and Technology Ethics Review and Services (Trial) (人工智能科技伦理审查与服务办法（试行）), 2026, Arts. 9, 12, 22 and 30 · Read the law's page

• Applies to universities, research institutions, medical and health institutions, enterprises and other units that carry out AI science research and technology development in China that may bring science and technology ethics risks in areas such as human dignity, public order, and life and health (Arts. 2 and 9).
• Set up an AI science and technology ethics committee with the staff, premises and funding it needs and measures that let it work independently; its members must include experts in AI technology, applications, ethics and law (Arts. 9 and 10).
• Before carrying out a covered AI activity, apply for ethics review to the unit's committee, or to a service center where the unit has no committee or its committee cannot do the review, submitting the activity plan, the ethics risk assessment with monitoring, prevention and emergency plans, and a written undertaking (Art. 12).
• Identify changes in ethics risk in time and report them to the committee or service center, which follows up on approved activities generally at intervals of no more than 12 months (Art. 17).
• For an activity on the expert re-review list (human-machine integration systems with a strong influence on behavior, mental state and health; algorithm models, applications and systems able to mobilize public opinion; highly autonomous automated decision systems in settings with safety or health risks), apply for expert re-review after the preliminary review; follow-up review of such an activity is generally at intervals of no more than 6 months (Arts. 21, 22 and 25 and the Annex).
• Register the committee and the activities on the re-review list on the national science and technology ethics management information registration platform and submit the previous year's committee work report and the report on the implementation of listed activities (Art. 30).
• Provide channels for reporting violations of AI science and technology ethics and handle reports under the rules (Art. 31).