In recent years, overseas generative AI tools such as Copilot, ChatGPT, Claude, and Gemini have gradually entered the daily operations of enterprises. From drafting emails and organizing data to internal collaboration and client communication, these tools have significantly enhanced efficiency. Simultaneously, enterprises operating within China—including subsidiaries established by multinational corporations—inevitably face a series of legal and compliance challenges when utilizing these foreign AI tools.
Under China’s current legal framework, legislators encourage the development and application of AI tools while maintaining cautious oversight. Existing Chinese AI-related legislation primarily imposes obligations on “AI service providers”. Nevertheless, ordinary users of AI tools are also subject to various compliance requirements. In particular, because online activities naturally involve cross-border networks and overlapping jurisdictions, enterprises in China that use AI tools
