The proposal opens a monthlong public consultation and signals Beijing’s latest push to balance innovation and safety. Moreover, the draft outlines sweeping duties for providers whose systems simulate a human personality. These duties cover labels, time-out alerts, and emergency escalation tools. Analysts consider the move another building block in China’s layered AI policy approach. It follows 2023 generative AI rules and 2025 labelling mandates. Consequently, domestic giants such as Baidu, Tencent, and ByteDance face another compliance sprint. This article unpacks the China interaction draft, highlights core requirements, and assesses commercial and ethical ramifications.

Draft Release Timeline Details

The CAC announced the consultation on 27 December 2025 through multiple state channels. Specifically, the China interaction draft opened for comment that day. Furthermore, the watchdog invited public feedback by email or post until 25 January 2026. Interested parties must reference clause numbers and provide contact details. Consequently, legal teams across the tech sector are already parsing the 42-article text.

• Draft published: 27 December 2025
• Comment deadline: 25 January 2026
• Email channel: nirenhua@cac.gov.cn
• Postal option: CAC, Beijing, 100000

Officials hint that the text will convert into binding regulation as early as mid-2026. These dates frame a rapid consultation window demanding swift responses. However, understanding the document’s substantive scope is even more pressing, which the next section addresses.

Scope And Service Definition

The draft targets “anthropomorphic interactive AI services” that mimic human personality, thinking, and communication. Moreover, the scope covers text, image, audio, and video outputs offered publicly within China. Providers must manage any feature that elicits emotional engagement, from virtual companions to voice assistants.

Importantly, purely functional chatbots that lack emotional cues may escape these obligations. Nationally, user welfare now sits under the ethics priority for algorithmic services. Nevertheless, the CAC advises firms to self-assess borderline cases and report uncertainties early. The China interaction draft repeatedly stresses lifecycle safety responsibilities, so ambiguity invites regulatory scrutiny.

This definition draws a bright regulatory perimeter around emotionally capable systems. Consequently, providers must inventory features before analysing detailed duties.

Core Provider Duties Explained

The China interaction draft imposes clear operational tasks across labeling, usage monitoring, data management, and security assessment. Firstly, every service must disclose that users converse with an algorithm, not a real person. Additionally, a pop-up reminder must appear when a session exceeds two continuous hours and at each login.

Secondly, providers must detect signs of addiction or extreme emotion. Therefore, scripts should encourage rest, suggest professional help, or escalate to human staff. Minors receive special attention: a dedicated mode limits usage time and requires guardian controls.

Data obligations are equally strict. Moreover, training datasets must reflect socialist values and undergo provenance checks. Providers hosting one million registered users or one hundred thousand monthly actives must file a security assessment with provincial CAC offices.

These duties blend technical safeguards with ideological content limits. Nevertheless, their business impact varies across industry tiers, as the following section explores.

Impact On Industry Players

Large platforms already maintain compliance teams and may absorb new costs smoothly. In contrast, smaller startups face heavier proportional burdens. Furthermore, mandatory emotion detection and real-time logging demand specialised talent and infrastructure. For startups, the China interaction draft could redefine funding priorities.

Industry lawyers warn that each additional policy stack increases time-to-market. Moreover, foreign vendors operating joint ventures must harmonise international privacy standards with domestic regulation specifics. Some commentators fear innovation chill if creative conversational designs trigger content red lines.

Key scale indicators highlight the stakes:

• 515 million generative-AI users reported nationwide in mid-2025
• Hundreds of registered AI companion products already filed with the CAC
• Two-hour pop-up rule influences millions of daily sessions

These numbers underscore why Beijing views anthropomorphic AI as a high-impact domain. Consequently, understanding the broader global context offers valuable perspective.

Global Policy Context Comparison

Several jurisdictions consider similar safeguards, yet China’s approach remains uniquely prescriptive. For example, the European Union AI Act emphasises risk tiers but rarely mandates emotion detection. Meanwhile, the United States relies on voluntary frameworks and sectoral privacy laws. Global debates on AI ethics rarely prescribe emotional safeguards so concretely.

Analysts therefore view the China interaction draft as part of a first-mover strategy. It allows the cyberspace watchdog to refine enforcement tools before foreign peers complete negotiations. However, tight ideology clauses complicate interoperability discussions with global firms. Unlike the EU, the China interaction draft marries content ideology with technical prescriptions.

This comparison highlights China’s preference for granular, enforceable text over broad principles. Nevertheless, compliance guidance remains evolving, which the next section translates into actionable steps.

Practical Compliance Next Steps

Legal teams should begin clause mapping immediately. Additionally, product leads can run gap analyses against existing generative AI controls. Security engineers must prototype two-hour timers, emotion classifiers, and exit buttons that function across devices. Today’s China interaction draft remains provisional, yet its direction is clear.

Firms meeting the user thresholds should draft security assessment dossiers early for provincial submission. Moreover, data teams need provenance logs ready to satisfy future audits. Professionals can enhance their expertise with the AI Foundation certification to navigate these technical demands.

Parallel ethics reviews should accompany every release candidate. These preparatory measures reduce last-minute firefighting and strengthen governance baselines. Consequently, organisations will be better positioned when the final measures arrive.

The China interaction draft marks another decisive leap in China’s AI governance journey. Moreover, its detailed labeling, emotion monitoring, and minor protections extend earlier regulation into the human-machine relationship itself. Industry players must adapt quickly because the cyberspace watchdog shows little tolerance for laggards. Nevertheless, proactive clause mapping, dataset hygiene, and early security filings can tame compliance risk. International observers will watch closely as policy innovation and ideological control intersect. Therefore, now is the moment for leadership teams to mobilise cross-disciplinary task forces. Explore the full text, engage in the consultation, and upskill with recognised credentials. Lastly, stay alert for revisions before the measures take effect.