China’s AI Governance: A Conversation with Professor Zhang Linghan

The Simon Institute (SI) is publishing periodic conversations with leading legal and policy experts to explore how different countries and regions are navigating the governance of AI, and how emerging domestic practices might inform international AI cooperation. 

In the first of the series, SI spoke to Professor Zhang Linghan about China’s approach to AI governance. Zhang is Director of the Institute of AI Law and Governance, China University of Political Science and Law, and was a member of the United Nations Secretary-General’s High-Level Advisory Body on AI. She is an expert member of committees at China’s Ministry of Industry and Information Technology and Ministry of Public Security and has participated in the drafting of many laws and regulations related to AI algorithms, data protection, and platform governance. In 2024, she led the drafting expert group of the China AI Law (Scholar Proposed Draft). The same year, she was named to TIME’s list of the world’s 100 most influential people in AI.

Key takeaways include:

1. China’s AI governance combines stable core priorities with procedural flexibility.
   Over the past seven to eight years, China’s AI governance has consistently prioritized information integrity, fair market competition, and labor and consumer protection. At the same time, regulators have adjusted governance tools in response to technological change, including through streamlining filing procedures for generative AI services and relying on departmental rules to maintain regulatory adaptability.
2. Expert participation is institutionalized in Chinese AI regulatory processes.
   The drafting of AI regulations typically involves academic experts from an early stage, with additional expert input incorporated before and during public consultation. This multi-stage consultation structure is a standard feature of China’s AI policymaking process.
3. Chinese AI governance is shaped by sustained comparative engagement with US and EU frameworks.
   Chinese experts closely track and reference international AI regulatory developments, particularly in the EU and the US. Comparative analysis informs domestic discussions on issues such as consumer protection, regulatory scope, and AI content labelling.
4. Extreme AI risks have been formally elevated, while frontier AI regulation remains difficult.
   The “AI Safety Governance Framework 2.0” places extreme risks in an important position within China’s AI policy architecture and outlines a non-binding blueprint for AI safety governance. At the same time, effective regulation of frontier AI is constrained by technical complexity and limited regulatory capacity, challenges that are widely shared across jurisdictions.
5. A high-level AI law is viewed as necessary to address structural legal constraints.
   China’s current reliance on departmental rules cannot resolve conflicts with other existing laws. As a result, there is broad agreement that a national AI law is needed to amend, repeal, or reconcile incompatible legal provisions and to provide a coherent legal foundation for AI governance.

Download the full interview below. Views expressed are those of the interviewee and do not reflect the official policy or position of SI.