Last Friday, the Cyberspace Administration of China (CAC) released a list of the first batch of algorithm filings submitted by Chinese internet information service providers.

This is arguably the first opportunity for tech and other businesses to assess how the CAC expects its new algorithm filing system to be used, following its launch under China’s algorithm regulation on 1 March 2022.

Our initial observations are below:

• This first list covers submissions by 24 Chinese internet companies and suggests that many major players in the internet sector were the first to comply with the new regime – whether to meet internal or external expectations.
  
  
• Not surprisingly, all algorithms within this first batch power B2C services, as the regulation focusses on the protection of users’ rights and interests which suggests that consumer-facing services will be a higher priority for enforcement action to ensure compliance.
  
  
• The list is broken down by algorithm. There are 30 algorithms covered in the first batch and each piece of coding could be used in different services. The algorithms in Friday’s list are used by 37 apps, 11 websites and 4 mini programs. The heavy weighting towards apps reflects the greater regulatory scrutiny that continues to apply to this product type.
  
  
• Aligned with the defined scope of algorithm technology under the regulation, the categories of the first batch of algorithm filings include algorithm technologies that can be used for data generation and synthesis, personalised push, selection sorting, search filtering and decision scheduling.
  
  As the algorithm filing requirement under the algorithm regulation is limited to algorithms which promote recommendation functions that could “shape public opinion” or “mobilise society”, we would expect the filings to mostly relate to news and other content-driven services.
  
  However, the first list also includes algorithms that recommend jobs or consumer products, arrange food delivery, and convert voice to text. Question if the expansive nature of the list shows that Chinese internet companies are eager to show their compliance credentials, or that provincial CACs are tending to interpret the algorithm regulation more broadly in their guidance to organisations on whether or not to file.
  
  
• One example filing of this nature is the only submission for a financial product or service – Futu’s content recommendation algorism within the popular stock information app, Futu NiuNiu. Based on the explicit scope of algorithms required to file with the CAC under the regulation, it is not clear if this type of algorithm in the financial industry must submit a filing or the action by Futu is out of prudence. Understanding the scope of algorithms caught by the filing requirement in practice will be crucial to compliance by other tech companies and beyond.