Interim Measures for Generative AI

Minors use our AI product -- what extra work does that require?

What you may need to do

1. Publish the intended users, occasions and purposes on the home page and on the relevant pages.
2. Design a time or frequency intervention mechanism for minors' use.
3. Tighten policy for content that may endanger physical or mental health.
4. Provide guardian notices and guidance on use.
5. Assess periodically whether the anti-addiction measures actually work.

Provisions relied on

One-line conclusion

For a public-facing AI service that minors may use, Article 10 requires three things: state clearly who the service suits, on what occasions and for what purposes; guide users towards rational use; and take measures to prevent minors from becoming over-reliant or addicted.

Basis

Article 10 states the requirement in one sentence with three layers: clearly state and publish the intended users, occasions and purposes; guide users towards a scientific and rational understanding and lawful use of generative AI technology; and take effective measures to prevent minor users from becoming over-reliant on or addicted to generative AI services.

Clearly state and publish is an action requirement, which means it cannot stay internal knowledge: the interface users see must explain who the service suits, in what scenario it is used and what it is used for. An image tool aimed at professional designers and an essay tool aimed at students should carry different statements of intended users.

Take effective measures is the obligation most easily left on paper. Effective means verifiable: is usage time tracked, does an intervention trigger, and does behaviour change after it triggers?

Article 4, item (4) supports the content side: respect the lawful rights and interests of others, do not endanger the physical or mental health of others, and do not infringe their rights to portrait, reputation, honour, privacy and personal information. In scenarios involving minors, the physical and mental health item calls for a stricter content policy.

Article 4, item (5) also requires effective measures based on the characteristics of the service type to improve the transparency of the service and to improve the accuracy and reliability of generated content. For scenarios minors use, transparency means making sure users understand that content is AI-generated and may be inaccurate.

What you need to do

1. Publish the intended users, occasions and purposes prominently. Do not bury them deep in the user agreement.
2. Assess whether minors may use the product. If it is open to the public, you cannot assume they will not.
3. Design dependency interventions: continuous-use time notices, late-night reminders, daily usage notices, and let users view their own usage records.
4. Tighten policy for content that may endanger physical or mental health, including guidance on self-harm, extreme emotion and appearance evaluation topics.
5. Provide guardian notices explaining what management options guardians have.
6. Look at the data regularly: intervention trigger rates and the distribution of usage time, to verify the measures work.

Common pitfalls

• Assuming it does not matter because the product is not aimed at students. If it is open to the public, consider whether minors can reach it.
• Writing a statement without building a mechanism. Article 10 requires effective measures, not one line of notice.
• Using push notifications and continuous interaction design to stretch usage time, which runs against anti-addiction.
• Treating anti-addiction as content filtering alone and ignoring the time and dependency dimensions.

Common follow-up questions

What should an anti-addiction measure actually look like? The Measures do not prescribe a uniform form; the requirement is to take effective measures to prevent over-reliance or addiction. Workable options include usage-time notices, time-of-day reminders, usage record queries and content grading. Follow your local cyberspace administration on the details.

Can a minor use the service without a guardian's consent? Article 10 does not directly set account admission rules. Where a minor's personal information is processed, the special provisions of the Personal Information Protection Law (个人信息保护法) and comparable laws also apply.

Does adding a notice inside the app count as an effective measure? A notice alone can hardly demonstrate effectiveness. It is better to have a mechanism that can be measured, triggered and reviewed.

Common follow-up questions

How should the service statement describe the intended users?

Under Article 10, all three elements -- intended users, occasions and purposes -- must be clearly stated and published. Write it specifically enough to name typical users and typical scenarios, and avoid a vague line claiming it suits all users.

Do anti-addiction measures need to be filed with the regulator?

The Measures do not require separate filing of an anti-addiction mechanism. A service with public opinion attributes or social mobilisation capacity carries out a security assessment and completes the algorithm filing procedure under Article 17. Follow your local cyberspace administration on the specifics.

Must content policy for minors be stricter?

Yes. Beyond Article 10, Article 4, item (4) requires not endangering the physical or mental health of others, and scenarios involving minors should tighten the generation policy for the related topics.

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