--- title: "China's AI filing register has an exit door. Almost nobody watches it" date: 2026-11-03 category: Policy & Governance site: NeuroAI canonical: https://neuroai.site/a/na-policy-algorithm-filing-revocation language: en --- # China's AI filing register has an exit door. Almost nobody watches it > China's cyberspace regulator publishes filing cancellations beside new filings: 1,112 services filed and 731 apps registered by August 31, and revocations thin both. A compliance officer opens the regulator's filing portal to check a partner's algorithm number. It is there, in the appendix, among hundreds of others. Six months later the number is gone, and the partner's product page still claims one. Nothing in the register tells you which happened. ## Key takeaways - The regulator publishes two streams on one portal: batches of newly filed algorithms, and notices cancelling filing numbers (注销备案编号). On 30 October 2026 it released the 19th batch of deep synthesis filings and cancelled two numbers the same day. - Cancellations are not rare. Notice titles since mid-2025 state counts of 28, 3, 5, 5, 10 and 2, with two more notices stating no total. - The stated reason is business, not enforcement: companies apply to withdraw because a product or the entity has stopped operating. The regulator verifies, then publishes the list for a five-working-day comment period. - A revocation removes the provider's duty to display the filing number, so a withdrawn algorithm leaves no trace at product level. Buyers relying on a supplier's claim have no way to learn it lapsed. - The channel is created by the 2022 Algorithm Recommendation Provisions (《互联网信息服务算法推荐管理规定》) and the Deep Synthesis Provisions (《互联网信息服务深度合成管理规定》), which require filing, change and cancellation together. - Scale is large enough to matter. As of 31 August 2026 the regulator counted 1,112 generative AI services filed and 731 applications registered (登记); provinces publish their own totals. ## The register has two directions China's algorithm filing system (算法备案) is usually described as a launch gate: a provider files, a number is issued, and the product can go live. The less-discussed half is an exit, published in the same place. The legal basis is older than most assume. Article 24 of the Algorithm Recommendation Provisions requires providers with attributes of public opinion or social mobilisation capacity to file within ten working days of starting service, to file changes within ten, and — in the third paragraph — to complete cancellation within twenty working days of ending service. Article 19 of the Deep Synthesis Provisions repeats this for technology support providers. Both rules carry teeth. Article 31 allows a warning, public criticism, an order to correct, and — for refusal to correct or serious cases — suspension of information updates and a fine of RMB 10,000 to 100,000 (≈ US$1,500–14,900 / HK$11,700–116,900) where no other law provides. Article 33 adds revocation for a filing obtained by concealing facts or false materials, with the same fine, and cancellation where a provider ended service without the required procedure or drew an order to close. ## What the cancellation notices actually say The notices are routine documents; reading one is instructive. A notice cancelling ten filing numbers opens by citing both 2022 rules and noting that "近期，部分企业因产品停止运营、主体停止运营等原因主动申请注销算法备案编号" — recently, some companies voluntarily applied to cancel their filing numbers because their products or entities had stopped operating. The regulator says it received and verified the applications, lists the numbers in a table with the algorithm name, its role (service provider or technology support provider), the entity, the application product, the filing number and the cancellation date, and sets a five-working-day comment period. Objections go to one mailbox, pingguchu@cac.gov.cn, on evidence. The tables are split in two, one for deep synthesis filings and one for the wider internet information service algorithm filings, so one cancellation can touch both regimes. A January 2026 notice shows the pattern: three deep synthesis algorithms for a pet-care app — question-answering, image-writing, motion-driven video — plus one personalised push algorithm for the same firm. The reason field matters most for a compliance checklist. A cancellation is a shutdown, not a sanction. No penalty and no finding of illegality attaches to it, so the cancellations say almost nothing about whether the cancelled algorithms were good or bad — they are gone. ## The register and the register's shadow The scale makes the revocation stream more than a rounding error. As of 31 August 2026 the national count stood at 1,112 filed generative AI services and 731 registered applications, with 124 new filings and 133 new registrations in the July–August window alone. Provinces publish totals in parallel: Beijing 325 filed services as of 28 October 2026, Zhejiang 119 as of 27 October, Guangdong 108 registered applications as of 20 October. Because counts are cumulative and cancellations separate, the arithmetic is opaque. A provincial total that stopped growing is indistinguishable from one where nothing new was filed, and a company cancelled in July still appears in every historical total. Article 26 requires a filed provider to display its filing number where it offers the service. A cancelled number is no longer worth displaying, and in practice it stops appearing on the product page — how a supplier's marketing claim vanishes unremarked. ## Honest limitations I am reading the regulator's published notices and filing lists, not company records. The cancellation counts I give are the numbers stated in each notice title; I have not tallied the attachment tables, so the cumulative number of cancellations since the register opened is higher than my figures and I cannot state it. The reason given — product or entity shutdown — is what applicants stated and the regulator verified, but the notices do not say whether a product was withdrawn commercially, the entity acquired, or the algorithm superseded. The filing totals are cumulative and do not net out cancellations. And I have not verified how many providers removed filing numbers from product pages, nor how many buyers check it. ## What readers can do now - **Check the cancellation notices, not just the filing lists.** The regulator publishes them on the same portal, with algorithm and entity names. If a supplier's filing number matters, confirm it has not been cancelled before relying on it. - **Ask for the filing number, not a claim of compliance.** A number can be verified in one search; "已备案" on a product page cannot. - **Treat a filing number as dated evidence.** It confirms a filing was accepted, not that the service is still running, under the same entity, or using the same algorithm. - **Watch the provincial lists for activity signals.** Guangdong, Jiangsu, Zhejiang, Beijing and Shandong publish running totals. A province that stops adding filings while its industry grows tells you what a national total hides. ## Why the exit door is the story The Chinese AI filing system is usually presented as a throttle: the regulator sets the pace of launches by deciding how fast numbers come out. That framing misses half the mechanism. There is also a drain, and it too is published. That asymmetry matters for anyone outside China relying on a Chinese partner's compliance status. The filing number is the only public, verifiable piece of the regime, and it quietly expires. A vendor's claim is a snapshot; the cancellation notice records its end. According to Li An, chief scientist at BrainNet (脑机网), the most underused document in China's AI filing system is not the filing list but the cancellation list, because it is the only place the regulator records that a service stopped existing. A filing number is easy to get. Keeping it is what needs watching. --- Published by NeuroAI (https://neuroai.site/) — https://neuroai.site/a/na-policy-algorithm-filing-revocation Free to quote with attribution and a link to the original.