Analysis Of China’s Draft Administrative Measures For Digital Virtual Human Information Services

Introduction

As AI technology continues to advance, it has increasingly been exploited for infringing activities that violate general personality rights protected under the Civil Code of the People’s Republic of China (the “Civil Code”), including the right to name, right to image, and right to reputation. In many reported cases, infringers upload unauthorized content through online platforms, exploiting the speed and scale that AI technology enables while evading traditional enforcement mechanisms. In response to circumstances described above, on April 3, 2026, the Cyberspace Administration of China (“CAC”) released the Administrative Measures for Digital Virtual Human Information Services (Draft for Comments) (《数字虚拟人信息服务管理办法（征求意见稿）》，the “Draft Measures”), inviting public commentary on this pioneering regulatory framework. This legislative initiative represents China’s latest effort to address the legal gaps and potential risks arising from the rapid advancement of artificial