Anthropomorphic AI Interaction Services: Consultation Draft vs. Final Measures

What changed

Material differences at a glance

The final measures convert the CAC consultation proposal into a joint five-authority rule, retain the core focus on dependency, minors, personal information and security assessment, and add a fixed effective date and a more developed lifecycle-governance structure.

The final rule is jointly issued by five authorities rather than presented as a CAC consultation proposal.
The final text expressly frames safety duties across deployment, operation, upgrade and termination.
The final text adds a fixed effective date of 15 July 2026 and operative penalty provisions.

Source comparison

5 reviewed change records

Article / Section	Previous Text	Updated Text	Type	Practical Impact	Notes
Issuing framework	The proposal was released by the CAC for public consultation.	The final measures were jointly issued by the CAC, NDRC, MIIT, Ministry of Public Security and SAMR.	~ Modified	Compliance ownership extends across a multi-authority governance framework.	Compare the publication announcements.Effective: 2026-07-15Previous source Current source
Lifecycle governance	The draft required provider safety-management systems and safeguards.	The final text expressly requires safety responsibilities across deployment, operation, upgrade and termination, together with monitoring, risk assessment and log retention.	i Clarified	Product governance should cover the complete service lifecycle rather than launch review alone.	Final Articles 9-10.Effective: 2026-07-15Current source
Minors	The draft addressed guardian consent, minors' data and protective settings.	The final rule expressly prohibits virtual-relative and virtual-partner services for minors and requires guardian consent before other services are provided to children under 14.	~ Modified	Age assurance, mode switching and service restrictions need to be implemented together.	Final Article 14.Effective: 2026-07-15Current source
User data controls	The draft required a deletion option for historical interaction data.	The final text expressly provides both copying and deletion options and restricts third-party provision of interaction data absent a legal basis or clear consent.	~ Modified	User-facing data controls should support export as well as deletion.	Final Article 16.Effective: 2026-07-15Current source
Legal status and penalties	The consultation draft contained no fixed commencement date.	The final rule took effect on 15 July 2026 and includes an operative enforcement and penalty provision.	+ Added	The obligations now have a fixed implementation date and enforceable consequence framework.	Final Articles 30 and 32.Effective: 2026-07-15Current source

Official sources

Previous source Current source

This website is for informational and educational purposes only. It does not constitute legal advice. The Chinese text shall prevail. Users should consult qualified legal counsel for specific matters.

Search laws, regulations, standards and guides