Interim Measures for Generative AI Services, Articles 2 and 7: training data must be lawfully sourced and personal information needs consent, for services offered to the public in China (Interim Measures for the Management of Generative Artificial Intelligence Services (Order No. 15, 13 July 2023, in force 15 Aug. 2023; Chinese text published by the Cyberspace Administration of China), Arts. 2(3) and 7(1) and (3))
Translation: the Measures do not apply to organisations that research and apply generative AI without offering generative AI services to the public in China; for providers they do apply to, training data must come from lawful sources and, where it involves personal information, must rest on the individual's consent or another ground in law. A US lab that trains abroad and does not serve the Chinese public is outside these Measures, but they show how Chinese authorities expect training data to be sourced, and the buyer may still ask a Chinese holder for proof of consent (my reading).
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“行业组织、企业、教育和科研机构、公共文化机构、有关专业机构等研发、应用生成式人工智能技术，未向境内公众提供生成式人工智能服务的，不适用本办法的规定。 ... （一）使用具有合法来源的数据和基础模型； ... （三）涉及个人信息的，应当取得个人同意或者符合法律、行政法规规定的其他情形；”
Figures it counts in
It is shown on its own, not counted into a figure.
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