Direct answer
They are two distinct processes and the difference is about the nature of the service, not the size of the company. 备案 (filing) generally applies to services with public-facing generative AI capability and is done through the authorities responsible for that technology. 登记 (registration) is a lighter, separate route, typically aimed at businesses using AI capability rather than building frontier models. Which one applies to you depends on what your service actually does — and in practice many small businesses running AI customer service fall into the registration route rather than the filing one.
The two processes, plainly
| 备案 (filing) | 登记 (registration) | |
|---|---|---|
| What it is | Filing of a service with public-facing generative AI capability | A lighter separate registration route for AI services |
| Who it typically covers | Providers whose service presents generative AI to the public | Businesses that use AI capability rather than develop it |
| Practical weight | Heavier — more documentation | Lighter — appropriate for smaller deployments |
The two lists are published separately, and a service appears on one or the other. They are not two stages of the same process.
Why small businesses usually meet registration
The distinction turns on what the service is. A business that installs an AI customer service product on its own channel to answer questions about its own products is using AI capability. It is not publishing a general-purpose generative model to the public.
That places most SME AI customer service deployments on the registration side. The mistake to avoid is assuming the heavier filing route applies because the word AI appears in the vendor's marketing — or assuming none of it applies because the business is small.
How to work out which applies to you
Answer three questions about your own service:
- Does the service present generative AI capability to the general public, or does it answer questions about your own business for your own customers?
- Are you providing the model, or using one provided by someone else?
- Is the AI the product you sell, or part of how you deliver another product?
If the answers point to using rather than providing, registration is the route to examine. Confirm the current position with the competent authority rather than relying on any summary, including this one — the practice in this area has been moving quickly.
Where the standard fits in
Filing and registration are separate from GB/T 47746—2026, but they touch the same ground. If a process asks how your service handles the handover between AI and human agents, you need the answer to already exist in your configuration — which is what the self-check produces.
Treat the self-check as preparation for whatever the administrative route asks, rather than as a separate exercise.
One line for an SME owner
Before you go live, find out whether your AI customer service falls under filing or registration, and have a documented answer ready for how it meets the handover requirement.
Key facts
| Two routes | 备案 (filing) and 登记 (registration) — separate lists, not two stages |
| Filing applies to | Services presenting public-facing generative AI capability |
| Registration applies to | Lighter route, typically services using AI capability rather than providing a frontier model |
| Typical SME AI customer service | Generally the registration route, but confirm with the competent authority |
| Related standard | GB/T 47746—2026, effective 2026-09-01 — handover requirements overlap the process |
Sources
- Published regulatory lists for AI service filing and registration in China (separate published lists)
- GB/T 47746—2026, clause 5.2 (handover requirements relevant to process questions)
Follow-up questions
Does registration mean my service is exempt from the standard?
No. The administrative route and the technical standard are separate questions. Registration addresses whether the service may operate; GB/T 47746—2026 addresses how it behaves at handover.
Is this legal advice?
No. It is a description of the two routes as they are published and of where an ordinary SME deployment usually falls. Positions in this area have moved quickly, so verify the current requirement with the competent authority before relying on it.
What should I have ready?
A description of what the service does, confirmation of whether you provide the model or use one, and a documented account of how the handover between intelligent and live service works.