The release checklist ends with a screenshot. Someone has to open the app, scroll to the page where the model is named, and capture the line that proves the service sits on a government register.
Nobody argues. The line goes on the page because the app stores check for it, and because every product in the category carries one.
What the number actually certifies is less well understood, including, sometimes, by the companies printing it.
Key takeaways
- China's cyberspace regulator counted 1,112 generative-AI services filed and 731 apps registered as of 31 August 2026 (CAC, 14 September 2026).
- The two-month window added 124 filings and 133 registrations, so the app layer is now growing slightly faster than the model layer.
- Filing is triggered by public reach, not by capability: only services with public-opinion or social-mobilisation attributes need a security assessment and an algorithm filing (Order No. 15, 2023).
- Provincial counts diverge sharply: Shanghai listed 255 registered apps on 15 October 2026 and Shandong 11, against 56 filed services in Shandong (provincial cyberspace offices).
- Enforcement runs off the register: a 2026 campaign that began in April handled more than 14,000 AI products, naming unfiled services as a first-phase target (Xinhua, 6 July 2026).
A register, not a rating
The instrument is the Interim Measures for the Administration of Generative AI Services (生成式人工智能服务管理暂行办法), a joint order of seven departments signed on 10 July 2023 and in force since 15 August 2023 (国家互联网信息办公室令第15号).
Two articles do the work. Article 2 limits the rules to services offered to the domestic public and excludes research and internal use. Article 17 requires a security assessment and an algorithm filing — 算法备案 — for services carrying public-opinion attributes (舆论属性) or social-mobilisation capacity (社会动员能力).
The list counted in the announcements is a separate register: the generative-AI service filing (生成式人工智能服务备案), run by the same regulator on the same trigger. It records who serves the public, and on which model. Nothing in it scores a model: a filed service can be excellent or mediocre. The artifact looks like a licence; it is closer to a company registration, establishing that someone accountable exists, at an address, serving a described product.
Two floors, and the second is filling faster
Two registers exist, and confusing them is the commonest foreign-coverage error.
The filing (备案) sits with the national regulator and attaches to the service — usually the model and its API. The registration (登记) sits with the provincial cyberspace office and attaches to an application or feature calling an already-filed model. An app built on a filed model still needs its own line.
The arithmetic:
- 30 June 2026: 988 filed services, 598 registered apps (CNNIC, 29 September 2026).
- 31 August 2026: 1,112 filed, 731 registered — a gain of 124 and 133 respectively in two months (CAC, 14 September 2026).
- Of the 124 July–August filings, 7 are generative-AI services that run on the phone rather than in a data centre (CAC).
The second floor is unevenly built. Shanghai's office counted 255 registered apps as of 15 October 2026, Jiangsu 117 as of 12 October, Guangdong 108 as of 20 October, and Shandong 11 alongside 56 filed services (provincial cyberspace offices). Those figures are dated later than the national total and cannot be added to it.
What the count measures, and what it does not
A count of 1,112 is a count of legal suppliers, not of competitors. Three things follow, and one warning.
- Structure, not scale. A thousand filings and seven hundred apps implies a long tail of small services on fewer models — the most useful thing the register reveals.
- Inflow without outflow. The regulator publishes additions. It does not publish withdrawals, so the stock includes services that have quietly stopped running.
- Geography as industrial policy. The provincial spread tracks local platform economies rather than local compute. Shanghai's count is twenty-three times Shandong's, which files more models than apps.
- The warning: none of this measures revenue, usage or quality, and no rejection rate or processing time has been published.
Where the gate actually bites
The number becomes real at the point of display. Services must show the model name together with the filing number (备案号) or the registration's launch number (上线编号) in a prominent place or on the product page (provincial cyberspace offices, October 2026). A missing line is checkable.
The register is also the lever. A campaign launched in April 2026 listed failure to carry out model filing and registration duties among its first-phase targets and reported more than 14,000 AI products handled, 6 million pieces of illegal or harmful information removed and 26,000 accounts actioned by 6 July (Xinhua). The second phase reported a further 5.61 million pieces, 49,000 accounts and more than 2,400 sites or applications by 2 September (CAC).
For an outside provider, two clauses decide the position. Article 20 allows the national regulator to notify relevant bodies to take technical and other measures against overseas providers that serve the domestic public without complying. Article 23 requires foreign-invested services to satisfy foreign-investment law as well. The register is therefore the entry artifact: a compliance statement without a number is not a status.
Honest limitations
The totals come from the regulator's own announcements and are not independently audited; there is no public reconciliation and no data on dormant filings. The registration tier is described in the provincial announcements that administer it rather than in a standalone article of Order No. 15, so its boundaries are inferred from practice, not from a single text. Provincial totals are later-dated than the national figure and cannot be summed into it. A filing number proves only that a filing exists; it says nothing about labelling, data handling or whether the product works.
What readers can do now
- Before any distribution or resale agreement, ask the partner for the 备案号 and the 上线编号, then check both against the regulator's lists. A product without either is outside the market, not early in it.
- Put the bi-monthly CAC announcement in the calendar: the next one, expected to cover September and October, carries the filing-to-registration ratio — the cheapest proxy for whether growth is moving to the application layer.
- In a market-sizing model, enter filed services as licensed suppliers and nothing else until usage or revenue data exists; a competitor count overstates every segment.