In a certification lab in Shenzhen, an engineer is building a dossier that used to be about hardware. Radio frequency, battery safety, charger compatibility — the stack of tests that stands between a handset and a shop shelf.
This year the folder carries an annex, and the annex is software. The assistant that ships switched on inside the phone has to be verified against the device it runs on, listed by model, and given an identity before sale.
The rule that put it there is not an artificial-intelligence statute. It is a licensing regime for telecom equipment that predates the smartphone.
Key takeaways
- The General Office of the Ministry of Industry and Information Technology published 工信厅信管〔2026〕42号 on 6 November 2026; the document is dated 24 October 2026.
- Scope: any telecom terminal with a factory-installed agent (智能体); the text names phones, tablets and wearables.
- Four gates: adaptation testing, type-approval testing, pre-approved over-the-air upgrades, and distribution rules for app stores.
- Agents "should" carry a unique identity code with reference to GB/Z 185—2026, a seven-part series published on 22 May 2026.
- The text names no transition period and no effective date, so the constraint arrives with the next product cycle.
The permit that was already there
A terminal that connects to a public telecoms network in China needs a network access licence (进网许可证) before sale, granted after type testing under the Telecom Equipment Network Access Measures (《电信设备进网管理办法》).
That regime was built for radios, not reasoning software, but it sits at the border of the market: a ministry that wants to change what ships does not need a new law, only one more line in the test specification.
The notice adds that line. In its words, terminals with a pre-installed agent "must carry out agent adaptation verification in accordance with the relevant standards during network-access testing" (须在进网检测中依据有关标准开展智能体适配验证).
Nothing in the text sets a capability threshold — no benchmark score, no accuracy floor. What is regulated is process, identity and the update channel.
Four gates, one dossier
The notice divides the work into four parts, each landing on a different party.
- Adaptation. The agent developer verifies the agent against device models and operating systems, publishes the verified list on the product's settings page, and submits that verification to app distribution platforms before listing.
- Type approval. The terminal must pass agent adaptation verification inside the network-access test, plus an anti-fraud risk assessment and a pre-assessment of anti-fraud capability (涉诈风险安全评估和反诈能力前置性评测), both grounded in the Anti-Telecom and Online Fraud Law. A major change must be reported to the ministry and re-tested.
- Over-the-air updates. The manufacturer files an upgrade plan naming the timing, scale, user group, business scenario, service content, business model, and the security and anti-fraud measures. After the upgrade it files a report. Only then, following expert evaluation organised by the ministry, may the service reach users.
- Distribution. App developers must declare, by electronic signature, whether they consent to being invoked by an agent; without that consent an agent may not force a call into a third-party app. Stores must show the compatibility list, refuse to serve incompatible models, and inspect what they already carry, ordering rectification or removal where verification is missing.
The third gate is the one foreign teams underestimate. A shipping product is not a finished compliance file: the update path is separately reviewed, before users see the new capability.
What the identity code is, and what it is not
The notice says agents "should be equipped with a unique identity code with reference to" the agent-interconnection national standard series (智能体互联系列国家标准). That series exists: GB/Z 185—2026, seven parts, published on 22 May 2026 under the direction of the industry ministry and drafted by the China Electronics Standardization Institute (CESI) with more than seventy organisations.
Part two covers the identity code. It uses the object-identifier system defined in GB/T 26231, requires one code per agent, and requires mutual authentication before two agents interact. Thirty organisations — among them AISpeech (思必驰), Lenovo, ZTE and ByteDance's Volcano Engine — received identity-code node certificates from the national OID registry in Shanghai on 31 August 2026 (China Daily, 4 September 2026).
Two details deserve care, because retellings drift here. GB/Z is a guiding technical document, not a mandatory standard. And the notice's verb is 参考 — with reference to — not 依据, in accordance with, which it uses in the same paragraph for the adaptation tests. The enforceable item is the test; the code is the target the test points at.
Who carries the cost
For a foreign handset maker, the practical question is not whether the assistant is good. It is whether the model's dossier contains a verification report, whether the settings page lists the right device models, and whether the next over-the-air feature must wait for a review slot.
Fixed cost is not neutral between competitors: a vendor with a domestic certification team absorbs one more test item; an importer without one buys that capacity in. Distribution repeats the asymmetry: a platform obliged to inspect listed agents prefers complete paperwork.
The ministry frames the notice as "inclusive and prudent" supervision, citing the 15th Five-Year Plan outline, which names AI phones as a category to develop. Both are true at once: the category is promoted, and the gate in front of it is made more specific.
Honest limitations
The notice is a general-office document, not a ministerial order, and it defers to "relevant standards" and to test methods the ministry said it would develop with the national telecoms research institute; those methods were not published alongside it, so the real test burden is not yet visible. No enforcement data exists. Whether foreign brands face the same scrutiny is untested, and no list of approved models has appeared. Translations are mine; the Chinese text governs.
What readers can do now
- Ask your distributor for the network-access dossier on the model you plan to sell; check whether it now includes an agent adaptation report and the model list in device settings.
- If you ship an agent rather than a handset, find out which organisation holds an identity-code node under GB/Z 185 and what it charges; the code will be requested even though the standard is advisory.
- Schedule over-the-air reviews. A filed plan and an expert evaluation now precede any user upgrade, which makes update cadence a regulatory variable.