8 Asian Legal Business | November 2024 As Chinese AI apps sweep overseas markets, they face regulatory and identity challenges 中国AI手机应用席卷海外市场， 面临多重监管、“身份”挑战 In the context of China’s rapidly growing digital economy and the integration of AI into everyday life, AI-driven mobile apps from China are making a substantial impact worldwide. Last year, ByteDance’s AI-powered video editing app CapCut reached 600 million global downloads and generated • Chinese-developed AI apps dominate global download charts, especially popular among younger users. 中国企业开发的AI手机应用占据全球下载榜前列，尤其受到年轻族 群追捧 • AI filing, cross-border data, and geopolitical risks become key risks. AI备案、数据跨境、地缘政治风险成为相关企业最关注的话题 nearly $130 million in revenue, solidifying ByteDance’s status as a giant in the Generative AI product landscape. Other top-ranked Chinese apps include ByteDance’s Hypic for photo editing, Question AI from Zuoyebang for educational assistance, and Talkie, a chat app from the Chinese startup MiniMax which Briefs CHINA TECH COLUMN has gained huge popularity among U.S. teens. Susan Ning, head of the compliance practice at King & Wood Mallesons, believes that Chinese AI apps’ expansion into global markets is driven primarily by a desire for commercial growth and increased market share. Due to the strict AI regulations at home, pursuing diverse markets has become a prevailing trend. In addition to general-purpose AI models, Ning observes a rise in industry-specific AI applications overseas. “Specialized applications can leverage data more effectively with lower computing costs, potentially unlocking new value and creating new vitality in the future,” she explains. Key legal challenges Starting in 2023, multiple jurisdictions have introduced AI-related regulations, adding to the challenges Chinese AI apps face abroad, particularly given the large volumes of data these apps collect and process, which remain under regulatory scrutiny. These challenges manifest in several key legal areas. One such issue is the filing requirements for AI models. “According to current Chinese regulations, whether an AI model must be registered domestically depends on whether it provides generative AI services with public opinion or social mobilization capabilities for Chinese audiences. If the service is exclusively for foreign users, theoretically, it’s not subject to filing requirements,” Ning explains. Even if domestic filing isn’t mandatory, Ning notes the potential for global change. With the implementation of the EU AI Act, similar filing or regulatory measures may become the worldwide standard for AI oversight. “The EU AI Act includes filing requirements for high-risk AI systems to be registered in an EU database before entering the market,” Ning points out. “As with the ‘Brussels Effect’ seen in data protection from the EU’s GDPR, other regions may also incorporate filing requirements as part of their AI regulations.” Another major issue involves data,
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