--- title: "China will test the agent inside the phone before the phone can be sold" date: 2026-11-09 category: Policy & Governance site: NeuroAI canonical: https://neuroai.site/a/na-policy-miit-agent-terminal-notice language: en --- # China will test the agent inside the phone before the phone can be sold > A MIIT notice on 6 November adds agent verification, agent IDs and OTA review to telecom terminal certification for phones, tablets and wearables. A phone that can order a car, book a table and pay for it without you touching the screen is a different kind of product from a phone that runs apps. Someone has to decide who is accountable when the agent gets it wrong, and at what point in the manufacturing process that decision is made. On 6 November, China's Ministry of Industry and Information Technology (工业和信息化部, MIIT) answered that question in a document about the least glamorous stage of the business: network access certification, the licence a device needs before it can connect to a public telecom network. The notice, numbered 工信厅信管〔2026〕42号, is titled *Notice on Strengthening Network Access Management for Agent Terminals*. It is procedural, and it will reshape product schedules for every phone maker shipping an on-device agent. ## Key takeaways - MIIT's general office issued the notice on **6 November 2026**, defining an "agent terminal" (智能体终端) as a phone, tablet or wearable with an agent pre-installed. - Devices must undergo **agent adaptation verification as part of network access testing**, plus an anti-fraud risk assessment and capability evaluation before certification. - Agents on those devices should carry a **unique identity code** with reference to the national agent-interconnection standards; the wording is "reference" (参考), not "must". - Any **over-the-air upgrade** to an agent must be submitted to MIIT as a plan, reported again afterwards, and reviewed by experts before the updated service goes to users. - App stores must obtain an **electronic-signature declaration** from developers on whether agents may invoke their apps, publish compatibility lists, and take down agents that fail adaptation checks. ## Four gates, in order The notice lays out four work items, and they map onto the life of a device. **Adaptation.** Agent developers must verify their software against specific device models, manage permission calls, communications capability, network and data security, user rights and task execution, and publish a compatibility list in the product's settings page showing which models and operating systems have passed. Before an agent is listed on an app store, the developer must submit that verification record. **Network access.** This is the substantive change. Devices with pre-installed agents must go through agent adaptation verification during the network access test, using the relevant standards, and must undergo a separate assessment for telecom fraud risk. Terminal makers must guarantee that the device certified is the device shipped — no swapping the agent after the licence is granted — and must file with MIIT and re-test if the agent changes materially. **Upgrades.** If a manufacturer wants to update an agent over the air, it must first submit a plan covering timing, scale, user cohort, scenarios, service content, business model, network and data security measures and anti-fraud measures. After the rollout it must submit a report; only then, following expert evaluation and consultation, may the service be offered formally to users. **Distribution.** App stores are made responsible for the last mile. They must get developers to declare, by electronic signature, whether they consent to agent invocation — and without that declaration an agent may not force access to an app. They must display compatibility information, refuse to distribute agents to incompatible models, and inspect listings, ordering rectification or removal. ## The identity code is the interesting part Buried in the second item is a sentence that connects this notice to the standards work of the past year: agents used on these terminals "should, with reference to the agent-interconnection series of national standards, be equipped with a unique identity code" (应参考智能体互联系列国家标准配备唯一身份码). That references the *Artificial Intelligence — Agent Interconnection* standards published in June 2026, which define an identity code as a kind of digital ID carrying a unique identifier, capability claims, owning organisation and validity period. Note the verbs. Certification and anti-fraud assessment are mandatory ("须"). The identity code is recommended by reference ("参考"). That difference tells you where the regulator is confident and where the technical standard is still settling: the ID scheme exists on paper, but the issuing nodes and registry are young. ## Why over-the-air updates get their own gate The OTA provision is the one device makers will find most operationally awkward, and it is the most revealing. A phone's agent can change substantially between the box and the user's pocket. Permissions widen, tool access expands, behaviour shifts with a model update. Traditional type approval certifies a frozen configuration; an agent is a moving target. Requiring a plan before rollout and a report after, with expert review in between, converts a software release into a regulated event. It also creates a paper trail: if an agent later misbehaves, the regulator has the upgrade submission that described what it was supposed to do. ## What it means for builders For a large phone maker, this is project management: add a verification workstream, keep a compatibility matrix, plan OTA windows around review. For a small agent developer, the burden is different. Demonstrating adaptation across device models and operating systems is expensive, and the app-store declaration requirement gives platforms a lever over third-party agents that call into their apps. ## What this notice is not It is not a law. It is a departmental normative document issued under China's telecom equipment regime, resting on the Network Security Law, Data Security Law, Personal Information Protection Law, Anti-Telecom Fraud Law, Telecom Regulations and the Measures for the Administration of Telecom Equipment Network Access. It is not a national standard either, though it points at one. And it is not a ban on agents: the stated aim is a "prudent and inclusive" environment in which AI is "used by people, serves people and is controlled by people" — a framing about user control rather than prohibition. No transition period or effective date appears in the text as published, which in practice means obligations attach from issuance and enforcement ramps up through the certification pipeline. ## Honest limitations I read the notice through full-text reproductions published by Jiemian, Sina and IT Home on 6 November, not a downloaded copy from miit.gov.cn, whose policy page I could not retrieve with the document attached; the document number 工信厅信管〔2026〕42号 and the four work items are consistent across those reproductions. There is no published implementation guidance, checklist or list of "relevant standards" for the adaptation test, so what a passing test requires in practice is unknown. It is unclear how the rules apply to agents downloaded after purchase rather than pre-installed, which is the majority case for users. The relationship between this notice and the separate algorithm-filing and generative-AI content rules is not addressed. No enforcement actions have been announced, so the compliance burden described here is prospective. ## What readers can do now - If you ship a device with an on-device agent, add adaptation verification and OTA review to the launch critical path now; certification queues are the usual cause of slipped dates. - Read the "reference" and "must" distinction carefully when scoping engineering work — the identity code is currently a design target, not a gate. - For app developers, decide your position on agent invocation and make it explicit; silence is treated as refusal under the distribution rules. --- Published by NeuroAI (https://neuroai.site/) — https://neuroai.site/a/na-policy-miit-agent-terminal-notice Free to quote with attribution and a link to the original.