2024 Annual Review and 2025 Outlook for TMT Regulation in China

• In the TMT sector, regulators aimed to maintain key priorities and momentum in areas such as the digital economy, social commerce, AI, and other emerging technologies
• AI was a particular focus, with China pushing onwards with its own regulatory framework, though with a piecemeal approach
• Shifts were also made to cross-sectorial laws such as for competition, and many lower-level regulations, implementing rules and standards were issued across tech, Internet services, media and entertainment
• Overall investment policies for both inbound and outbound projects were updated towards more openness, with eased rules for market access and listings

Regulation of the technology, media and telecoms (“TMT”) sector in China during 2024 largely maintained the priorities and momentum of recent years (including digital economy, AI, and other emerging technologies), as well as progressing updates to general-purpose laws, such as the Anti-Unfair Competition Law (“AUCL”) (反不正当竞争法), to keep pace with the online ecosystem. There has also been a steady stream of lower-level implementing rules and standards, intended to create consistency for both regulators and companies.

Further, while there were ostensible liberalizations in some sub-sectors to spur economic growth and foreign investment (e.g., value-added telecom services and digital trade), in practice key restrictions remain in place, meaning 2024 did not bring material changes to market access trends. Overall, expectations for both companies and market are similar to those in past years, with the caveat that global political tensions are continuing to create fertile ground for surprise legislation in sensitive sectors.

1. Regulatory Framework

For TMT in 2024, the overall regulatory framework remains unchanged: