China’s Interim Measures for the Administration of Anthropomorphic AI Interaction Services: A New Phase in the Regulation of Human–AI Interaction
China’s interim measures set requirements for AI services offering sustained emotional interaction, with heightened protections for minors, data and user safety.
Summary
A client briefing from the law firm Hogan Lovells describes China's Interim Measures for the Administration of Anthropomorphic AI Interaction Services and what they demand of providers, including foreign businesses active in the country. The firm presents the rules as firm limits for companies offering AI products that behave like a person and build an emotional bond with users.
Coverage turns on three elements: imitation of human personality traits, interaction that continues over time, and emotional engagement. Continuity is described as the deciding factor, so customer service tools, question-and-answer systems, workplace assistants, educational platforms and research applications fall outside. A security assessment must be filed when a service launches or gains functions, when new technology significantly changes it, when it passes 1 million registered users or 100,000 monthly active users, or when national security or public interest risks arise. Providers must also complete algorithm filings and sign up users under agreements that collect details such as age, guardian and emergency contact.
On substance, the briefing stresses protection of children. Virtual companion or family-member relationships may not be offered to minors, parental consent is needed for users under 14, and special minor modes must include time limits, reminders to return to the real world and stronger parental controls. Providers must spot extreme emotional states and apply tiered responses where self-harm, suicide or major financial loss is possible. Outputs must follow Chinese law and ethical norms, and sensitive interaction data may be used for training only with separate explicit consent. App stores must verify filings and can warn, suspend or remove non-compliant apps.
Hogan Lovells adds that regulators encourage uses in elderly care, childcare and support for vulnerable people, and it advises foreign firms to scope products early and map obligations.