Manage user content through review procedures, reporting channels, and prompt action on unlawful information
Chinese platforms have their own content-management obligations. Establish procedures for registration, posts, comments, ongoing monitoring, and incident response. Put a reporting button where users can easily find it. On discovering unlawful information, promptly stop its transmission, preserve records, and report to the competent authority. Failure can bring RMB 50,000–500,000 fines, with higher penalties for more serious cases.
What it takes
Content moderation can be a major continuing staffing expense. Maintain a visible reporting route and records of actions taken. The work requires daily attention.
What you may gain
The content governance provisions require platforms to assume responsibility for information-content management and establish systems for registration, account management, publication review, comment review, page and interface content management, real-time monitoring, emergency response, and handling online rumors and information connected with illicit industries. They require convenient, prominently placed complaint and reporting channels. On discovering unlawful information, platforms must take lawful action immediately, preserve records, and report to the competent departments. The Cybersecurity Law specifically requires stopping transmission of information prohibited by law or administrative regulations, removing it or taking other measures to prevent spread, preserving records, and reporting. Failure can bring correction orders, warnings, public notice, and optional fines of RMB 50,000–500,000. Refusal to correct or serious circumstances can bring RMB 500,000–2 million fines, suspension for rectification, website or app closure, or revocation of business or operating licenses. Directly responsible individuals face separate RMB 50,000–200,000 fines. These are Chinese national requirements.
Context & considerations
Article 15 of the internet information services measures lists nine prohibited content categories and provides a starting point for moderation rules. Livestreaming adds requirements for a content-review platform, the ability to interrupt a live stream immediately, and retention of livestream content and logs for 60 days. Online performance recordings likewise require at least 60 days' retention. A platform's statutory management duties should not be confused with a blanket statement that it is automatically liable for every act by every user.
Research & references
Cyberspace Administration of China (2019). Provisions on the Governance of the Online Information Content Ecosystem, Order No. 5, Articles 8, 9, 10, 16, and 37. http://www.cac.gov.cn/2019-12/20/c_1578375159509309.htm; Standing Committee of the National People's Congress (2025). Cybersecurity Law, 2025 amendment effective January 1, 2026, Articles 49 and 69. https://www.cac.gov.cn/2025-12/29/c_1768735112911946.htm; State Council (2000). Measures for the Administration of Internet Information Services, Articles 15, 16, and 23. https://www.gov.cn/gongbao/content/2011/content_1860864.htm