Overview & Analysis
The AI Safety Governance Framework 1.0 is a foundational Chinese policy document for governing AI safety across the full lifecycle of AI development and deployment. It is built around a "people-centered, AI for good" approach and explicitly stresses that development and security should be advanced together. Using a risk-management lens, it maps the risks that can arise during design, development, training, testing, deployment, use, and maintenance. The framework covers not only intrinsic AI risks such as poor interpretability, bias, weak robustness, tampering, and adversarial attacks, but also risks relating to training data, computing infrastructure, supply chains, and AI applications in the network, real-world, cognitive, and ethical domains. In that sense, it is not merely a document about content moderation or model safety; it is a broader framework for technical risk, application risk, and governance responsibility.
Its importance lies in the way it sets out China's policy logic for balancing AI innovation with safety governance. On the one hand, it supports AI innovation and application; on the other, it calls for mechanisms such as classified and tiered management, traceability of AI services, data and personal information protection, supply chain safeguards, interpretability research, emergency response, industry self-discipline, and public oversight. Legal analysis has generally treated the framework as a foundational technical-governance guide and a strong signal of regulatory direction: China is moving toward lifecycle-wide, risk-based, and multi-stakeholder AI governance.
Intrinsic AI Risks
- Poor interpretability
- Bias & discrimination
- Weak robustness
- Theft & tampering
- Unreliable / hallucinated output
- Adversarial attacks
Data Security Risks
- Illegal data collection & use
- Training data poisoning
- Non-standard annotation
- Data leakage
- IP infringement in training data
System & Supply Chain Risks
- Defects & backdoors
- Computing power security
- Global supply chain disruption
- Cross-boundary compute-layer risks
Application Risks
- Misinformation & authentication bypass
- Cyberattack misuse
- Defect propagation via model reuse
- Cognitive warfare
- Social discrimination & loss of control
The framework is relevant in most major enterprise AI scenarios in China, especially where companies are developing models, preparing training data, offering AI services to the public, deploying AI in critical sectors, operating across borders, integrating third-party models, or managing higher-risk use cases. It assigns responsibilities to developers, service providers, key-sector users, and the public — making it relevant both to companies that build AI and those that procure, integrate, or operate it.
1. Developing, Training, Fine-Tuning, or Reusing Foundation Models
The framework directly addresses risks such as poor interpretability, bias, weak robustness, unreliable output, theft or tampering, and adversarial attack, and explicitly notes that defects in a foundation model can propagate downstream through reuse. Any company doing model development, fine-tuning, or secondary development in China should treat the framework as a key reference point for risk identification, testing, and responsibility allocation.
2. Preparing Training Data, Labeling Data, or Managing Data Flows
The framework stresses that training data and interaction data must comply with data-security and personal-information protection rules throughout collection, storage, use, transmission, disclosure, and deletion. It also highlights poisoning risk, leakage risk, non-standard labeling, unlawful sourcing, and intellectual property concerns. Data governance is not secondary to AI governance — it is central to it.
3. Providing Public-Facing AI Services, Content Generation, or Synthetic Media
The framework calls for a traceability management regime for AI systems serving the public and supports labeling requirements for AI-generated or synthesized content so that users can assess source and authenticity. Any public-facing AI service in China may need to consider product labeling, provenance controls, audit trails, and user communication measures to reduce risks of deception, impersonation, and bypass of authentication systems.
4. Deploying AI in Finance, Healthcare, Transport, Industrial Settings, or CII
The framework treats these as more sensitive deployment environments and expects prudent assessment, risk grading, regular audits, access control, backup and recovery planning, encryption, human supervision, and readiness to switch to manual systems. AI in high-impact settings cannot be judged only on efficiency or accuracy — it must also demonstrate safety, reliability, controllability, and emergency handling capability.
5. Cross-Border AI Services, Global Supply Chains, or Third-Party AI Procurement
The framework expressly states that cross-border provision of AI services must comply with China's cross-border data rules, that outbound provision of AI models and algorithms must comply with export-control requirements, and that supply chain risks around chips, software, tools, compute, and data resources must be monitored. China AI projects must be reviewed not only for model performance but also for data transfers, supply-chain resilience, third-party dependency, and traceable responsibility chains.
AI compliance in China should not be treated only as a content-control issue or narrow data-compliance exercise. It should be treated as a broader governance topic covering models, data, systems, supply chains, application scenarios, user communication, and incident response. The key is a tiered, standardized, and traceable governance model so that low-risk projects move quickly while higher-risk ones are identified early and subjected to deeper review.
Move Safety Governance to Project Intake, Not Pre-Launch
Require each AI project to answer a small set of intake questions at the outset: Is it public-facing? Does it process personal information or important data? Does it affect high-impact decisions? Does it rely on a foundation model or third-party model? Is it used in a sensitive sector? Are there cross-border data or export-control implications? The earlier the company identifies the scenario, the less likely it is to face rework or delays later.
Build a "Tiered Governance + Fast/Slow Lane" Operating Model
Stratify projects by risk. Low-risk internal productivity tools can use light-touch review templates and fast approval; medium-risk projects should involve joint review by business, data, legal, and information security teams; high-risk projects should require stronger testing, logging, explainability, human intervention, rollback design, and senior sign-off. The framework expressly calls for classified and tiered management of AI applications.
Treat Data Governance as the Foundation of AI Governance
Push data questions to the beginning of product and model development. Teams should be able to explain where training and inference data comes from, whether it is authentic, accurate, objective, diverse, and lawfully sourced, whether it includes sensitive personal information or important data, whether there are intellectual property issues, and whether it could introduce bias or poisoning risk. Many China AI projects stall not because of model design, but because data provenance is unclear.
Conduct "Responsibility Chain" Review for Third-Party Models & Vendors
The framework specifically says service providers should examine responsibility documentation from developers and ensure that responsibility can be traced through recursively adopted AI models. AI procurement cannot be reduced to functionality and price. Ask who built the underlying model, what the training data and limitations are, how security flaws are remediated, how outputs are labeled, and who is accountable if something goes wrong. Responsibility does not disappear because a third-party model is used.
Put Transparency, Labeling & Explainability into Product Design
The framework calls for appropriate disclosure of principles, capabilities, applicable scenarios, and safety risks, clear labeling of outputs, and explanation plans where AI decisions have major impacts. When is the user told they are dealing with AI? Are synthetic outputs marked? Can important outputs be explained in plain terms? Can internal teams quickly explain why a system produced a certain result? This both meets regulatory expectations and reduces user confusion and complaint risk.
In Key Sectors, Insist on Human Control and Manual Fallback
For healthcare, transport, industrial operations, public services, government, and critical information infrastructure, the framework strongly emphasizes human authorization, human supervision, and the ability to switch to manual or traditional systems in time. Treat this as an operational requirement: critical systems should have defined human approval points, shutdown rights, fallback procedures, escalation paths, and drills.
Integrate Cybersecurity, Supply-Chain Security & AI Safety into One View
The framework expressly mentions chips, software, tools, compute resources, data resources, vulnerabilities, backdoors, cross-boundary compute-layer risks, and supply disruption. China AI governance should not sit with an isolated "AI lead" alone — it should involve AI teams, the CISO function, procurement, legal, data governance, and business owners together, using one shared risk map and escalation structure.
Build Incident Response and Reporting Readiness Before Launch
The framework calls for risk-threat information sharing and emergency response mechanisms for AI security incidents, and says service providers should promptly report security incidents and vulnerabilities. AI systems should launch with log retention, risk monitoring, alert thresholds, shutdown authority, internal escalation matrices, and external reporting paths already defined. Effective governance means the ability to detect, contain, fix, and document the company's response quickly and credibly.
Keep Global Principles, but Localize the China Implementation Layer
Many multinationals have global AI principles, but China's framework is more specific on traceability, obligations for users in key sectors, cross-border AI services, model responsibility chains, and supply-chain security. Add a China implementation annex under the global framework: define which projects require local review, which scenarios require Chinese-language documentation, which vendor clauses are mandatory, and which China-facing features need labeling, restrictions, or human review.
The most practical value of this framework is not that it gives a single rigid blacklist of prohibited conduct, but that it offers an operating logic: manage AI through risk, combine technical and managerial controls, connect the responsibilities of developers, providers, users, and oversight actors, and treat model security, data security, system security, and application security as one governance structure. When those principles are turned into project tiering, data review, vendor admission standards, product labeling, human control design, and incident response processes, companies can scale AI in China more confidently without forcing a false choice between speed and compliance.
Complete Framework Text
Table of Contents
- Article 1 — Principles of AI Security Governance
- Article 2 — Structure of the AI Security Governance Framework
- Article 3 — Classification of AI Security Risks (Intrinsic)
- Article 4 (Part I) — AI Application Security Risks
- Article 4 (Part II) — Technical Countermeasures
- Article 5 — Comprehensive Governance Measures (10 measures)
- Article 6 — Guidelines for Safe Development & Application
(b) Establish and implement secure development standards during design, development, deployment, and maintenance to eliminate security defects and discriminatory tendencies in models and algorithms as much as possible and improve robustness.
(b) Strengthen intellectual property protection, preventing infringement during training data selection and output generation.
(c) Strictly screen training data to ensure that it does not contain sensitive data related to high-risk areas such as nuclear, biological, chemical, or missile weapons.
(d) If training data contains sensitive personal information or important data, strengthen data security management and comply with relevant standards and regulations.
(e) Use training data that is authentic, accurate, objective, diverse, and lawfully sourced, and promptly filter out invalid, erroneous, or biased data.
(f) Provision of AI services across borders shall comply with cross-border data regulations, and provision of AI models and algorithms abroad shall comply with export control requirements.
(b) For platforms aggregating multiple AI models or systems, strengthen risk identification, detection, and protection to prevent malicious behavior or attacks from affecting hosted systems.
(c) Strengthen the security construction, management, and operation of AI computing platforms and system services, ensuring uninterrupted operation of infrastructure and services.
(d) Closely monitor supply chain security for chips, software, tools, computing power, and data resources; track vulnerabilities and defects in hardware and software; and promptly implement patches and reinforcement measures to ensure system security.
(b) Establish data safeguards to ensure that AI system outputs involving sensitive personal information and important data comply with relevant laws and regulations.
(b) Enhance traceability of AI system end uses to prevent misuse in high-risk scenarios such as the development of weapons of mass destruction.
(b) Strictly prevent misuse of AI systems that analyze user queries to infer identity, preferences, or ideological tendencies.
(c) Strengthen research and development of detection technologies for AI-generated synthetic content, enhancing capabilities to prevent, detect, and respond to cognitive warfare tactics.
(d) In algorithm design, model training and optimization, and service provision, methods such as training data screening and output validation shall be adopted to prevent discrimination based on ethnicity, belief, nationality, region, gender, age, occupation, health, and other factors.
(e) AI systems applied in key sectors — such as government departments, critical information infrastructure, and fields that directly affect public safety and the life and health safety of citizens — shall possess efficient and precise emergency control measures.
(2) In contracts or service agreements, inform users of the scope of application, precautions, and contraindications of AI products and services in a manner easily understandable to users, and support users in making informed choices and using them prudently.
(3) In informed consent documents and service agreements, support users in exercising responsibilities for human supervision and control.
(4) Enable users to understand the accuracy of AI products, and, where AI decisions have a major impact, prepare plans for explanation and clarification.
(5) Examine the responsibility documentation provided by developers to ensure that the chain of responsibility can be traced back to recursively adopted AI models.
(6) Establish and improve real-time risk monitoring and management mechanisms, and continuously track security risks during operation.
(7) Assess the ability of AI products and services to resist or overcome adverse conditions when facing abnormal conditions such as failures and attacks, prevent unexpected results and behavioral errors, and ensure a minimum level of effective functionality.
(8) Promptly report security incidents, security vulnerabilities, and the like discovered during the operation of AI systems to the competent authorities.
(9) Clearly stipulate in contracts or service agreements that, once misuse or abuse inconsistent with the intended use and stated limitations is discovered, the service provider has the right to take corrective measures or terminate the service in advance.
(10) Assess the impact of AI products on users, and prevent harm to users' physical and mental health, life, property, and other interests.
(2) Based on the applicable scenarios, safety, reliability, and controllability of AI systems, regularly conduct system audits and strengthen awareness of risk prevention and capacity for risk response.
(3) Before using AI products, comprehensively understand their data processing and privacy protection measures.
(4) Use high-security-level password strategies, enable multi-factor authentication mechanisms, and enhance account security.
(5) Strengthen capabilities in cybersecurity and supply chain security, reduce the risks of AI systems being attacked and important data being stolen or leaked, and ensure uninterrupted business operations.
(6) Reasonably restrict AI systems' access permissions to data, formulate data backup and recovery plans, and regularly inspect data processing workflows.
(7) Ensure that operations comply with confidentiality requirements and use protective measures such as encryption technologies when processing sensitive data.
(8) Effectively supervise AI behaviors and impacts, ensuring that the operation of AI products and services is based on human authorization and remains under human control.
(9) Avoid complete reliance on AI decisions, monitor and record situations in which AI decisions are not adopted, analyze inconsistencies in decision-making, and possess the ability to switch in a timely manner to manual or traditional systems in the event of accidents.
(2) Before use, carefully read product contracts or service agreements, understand the functions, limitations, and privacy policies of the products, accurately recognize the limitations of AI products in making judgments and decisions, and reasonably set expectations for use.
(3) Enhance awareness of personal information protection and avoid inputting sensitive information where unnecessary.
(4) Understand the data processing methods of AI products and avoid using products that do not comply with privacy protection principles.
(5) When using AI products, pay attention to cybersecurity risks and avoid allowing AI products to become targets of cyberattacks.
(6) Pay attention to the impact of AI products on children and adolescents, and prevent addiction and excessive use.
人工智能安全治理框架
全国网络安全标准化技术委员会,2024年9月
目 录
(2)在设计、研发、部署、维护过程中建立并实施安全开发规范,尽可能消除模型算法存在的安全缺陷、歧视性倾向,提高鲁棒性。
(2)加强知识产权保护,在训练数据选择、结果输出等环节防止侵犯知识产权。
(3)对训练数据进行严格筛选,确保不包含核生化导武器等高危领域敏感数据。
(4)训练数据中如包含敏感个人信息和重要数据,应加强数据安全管理,符合数据安全和个人信息保护相关标准规范。
(5)使用真实、准确、客观、多样且来源合法的训练数据,及时过滤失效、错误、偏见数据。
(6)向境外提供人工智能服务,应符合数据跨境管理规定。向境外提供人工智能模型算法,应符合出口管制要求。
(2)对聚合多个人工智能模型或系统的平台,应加强风险识别、检测、防护,防止因平台恶意行为或被攻击入侵影响承载的人工智能模型或系统。
(3)加强人工智能算力平台和系统服务的安全建设、管理、运维能力,确保基础设施和服务运行不中断。
(4)对于人工智能系统采用的芯片、软件、工具、算力和数据资源,应高度关注供应链安全。跟踪软硬件产品的漏洞、缺陷信息并及时采取修补加固措施,保证系统安全性。
(2)应建立数据护栏,确保人工智能系统输出敏感个人信息和重要数据符合相关法律法规。
(3)根据用户实际应用场景设置服务提供边界,裁减人工智能系统可能被滥用的功能,系统提供服务时不应超出预设应用范围。
(4)提高人工智能系统最终用途追溯能力,防止被用于核生化导等大规模杀伤性武器制造等高危场景。
(5)通过技术手段判别不符合预期、不真实、不准确的输出结果,并依法依规监管。
(6)对收集用户提问信息进行关联分析、汇聚挖掘,进而判断用户身份、喜好以及个人思想倾向的人工智能系统,应严格防范其滥用。
(7)加强对人工智能生成合成内容的检测技术研发,提升对认知战手段的防范、检测、处置能力。
(8)在算法设计、模型训练和优化、提供服务等过程中,应采取训练数据筛选、输出校验等方式,防止产生民族、信仰、国别、地域、性别、年龄、职业、健康等方面歧视。
(9)应用于政府部门、关键信息基础设施以及直接影响公共安全和公民生命健康安全的领域等重点领域的人工智能系统,应具备高效精准的应急管控措施。
(2)服务提供者应在合同或服务协议中,以使用者易于理解的方式,告知人工智能产品和服务的适用范围、注意事项、使用禁忌,支持使用者知情选择、审慎使用。
(3)服务提供者应在告知同意、服务协议等文件中,支持使用者行使人类监督和控制责任。
(4)服务提供者应让使用者了解人工智能产品的精确度,在人工智能决策有重大影响时,做好解释说明预案。
(5)服务提供者应检查研发者提供的责任说明文件,确保责任链条可以追溯到递归采用的人工智能模型。
(6)服务提供者应提高人工智能风险防范意识,建立健全实时风险监控管理机制,持续跟踪运行中安全风险。
(7)服务提供者应评估人工智能产品与服务在面临故障、攻击等异常条件下抵御或克服不利条件的能力,防范出现意外结果和行为错误,确保最低限度有效功能。
(8)服务提供者应将人工智能系统运行中发现的安全事故、安全漏洞等及时向主管部门报告。
(9)服务提供者应在合同或服务协议中明确,一旦发现不符合使用意图和说明限制的误用、滥用,服务提供者有权采取纠正措施或提前终止服务。
(10)服务提供者应评估人工智能产品对使用者的影响,防止对使用者身心健康、生命财产等造成危害。
(2)重点领域使用者应根据人工智能系统的适用场景、安全性、可靠性、可控性等,定期进行系统审计,加强风险防范意识与风险应对处置能力。
(3)重点领域使用者在使用人工智能产品前,应全面了解其数据处理和隐私保护措施。
(4)重点领域使用者应使用高安全级别的密码策略,启用多因素认证机制,增强账户安全性。
(5)重点领域使用者应增强网络安全、供应链安全等方面的能力,降低人工智能系统被攻击、重要数据被窃取或泄露的风险,保障业务不中断。
(6)重点领域使用者应合理限制人工智能系统对数据的访问权限,制定数据备份和恢复计划,定期对数据处理流程进行检查。
(7)重点领域使用者应确保操作符合保密规定,在处理敏感数据时使用加密技术等保护措施。
(8)重点领域使用者应对人工智能行为和影响进行有效监督,确保人工智能产品和服务的运行基于人的授权、处于人的控制之下。
(9)重点领域使用者应避免完全依赖人工智能的决策,监控及记录未采纳人工智能决策的情况,并对决策不一致进行分析,在遭遇事故时具备及时切换到人工或传统系统等的能力。
(2)社会公众应在使用前仔细阅读产品合同或服务协议,了解产品的功能、限制和隐私政策,准确认知人工智能产品做出判断决策的局限性,合理设定使用预期。
(3)社会公众应提高个人信息保护意识,避免在不必要的情况下输入敏感信息。
(4)社会公众应了解人工智能产品的数据处理方式,避免使用不符合隐私保护原则的产品。
(5)社会公众在使用人工智能产品时,应关注网络安全风险,避免人工智能产品成为网络攻击的目标。
(6)社会公众应注意人工智能产品对儿童和青少年的影响,预防沉迷及过度使用。