Procurement workflow surface
Interim Measures for Generative AI Service Management — vendor disclosure form
This is a sample disclosure form a procurement team can adapt for vendor RFPs and ITTs evaluating systems against Interim Measures for Generative AI Service Management. The provision-specific questions below were derived from the catalog's coverage cells; before issuing, a qualified procurement lawyer should review the adapted version against your jurisdiction's contract law. This form is NOT legal advice (see charter §7.4).
1. Vendor identification
2. AI system identification
3. Provision-specific questions
- Foundation Models / GPAI. Does the offered system meet the threshold for a general-purpose / foundation model under Interim Measures for Generative AI Service Management (Art. 2 (applies to GenAI services regardless of size))? If yes, identify the specific obligations you will satisfy and the evidence you will provide.
(Cite: Art. 2 (applies to GenAI services regardless of size))
- Deepfakes / Synthetic Content. Does the offered system generate or substantially modify audio / video / image / text in ways requiring disclosure or machine-readable provenance under Interim Measures for Generative AI Service Management (Art. 12 (labelling) + Deep Synthesis Rules)? Describe the disclosure + provenance mechanisms implemented and their robustness against removal.
(Cite: Art. 12 (labelling) + Deep Synthesis Rules)
- Transparency Obligations. Provide the documentation required under the transparency obligations of Interim Measures for Generative AI Service Management (Art. 4 + Algorithm Recommendation Rules — disclosure to CAC, not public; conflicts with EU public-disclosure model) — including (as applicable) model card, system card, training-data summary, evaluation results, and known limitations.
(Cite: Art. 4 + Algorithm Recommendation Rules — disclosure to CAC, not public; conflicts with EU public-disclosure model)
- Individual Redress. Describe the end-user redress + complaint channel offered for the system, including documented appeal path and response-time commitment, consistent with Interim Measures for Generative AI Service Management (Art. 15 (complaint channels)).
(Cite: Art. 15 (complaint channels))
- Training-Data Rights. Identify the legal basis for training-data sourcing for the offered system (including copyright, consent, and any text-and-data-mining exemptions relied upon) and confirm consistency with Interim Measures for Generative AI Service Management (Art. 7 (legal source + IP requirements)).
(Cite: Art. 7 (legal source + IP requirements))
- Sovereign AI Doctrine. Describe the offered system's compliance posture relative to the Interim Measures for Generative AI Service Management provisions identified at: Art. 17 (registration + algorithm filing).
(Cite: Art. 17 (registration + algorithm filing))
- Technological Sovereignty. Describe the offered system's compliance posture relative to the Interim Measures for Generative AI Service Management provisions identified at: Art. 4 + national-strategy alignment; domestic-AI doctrine explicit.
(Cite: Art. 4 + national-strategy alignment; domestic-AI doctrine explicit)
- Synthetic Content Provenance. Does the offered system generate or substantially modify audio / video / image / text in ways requiring disclosure or machine-readable provenance under Interim Measures for Generative AI Service Management (Art. 12 — mandatory marking of generative-AI output; aligns with Deep Synthesis Rules (2022) tagging requirements)? Describe the disclosure + provenance mechanisms implemented and their robustness against removal.
(Cite: Art. 12 — mandatory marking of generative-AI output; aligns with Deep Synthesis Rules (2022) tagging requirements)
4. Documentation enclosures expected
Tick each enclosure attached to the vendor response. Missing enclosures should be explained in the “Variances” field below.
- Content provenance + watermarking technical description
- End-user redress + complaint-channel procedure
- Copies of submitted regulatory reports / registrations
- Safety / capability evaluation results
- Vendor company registration + insurance certificates
- Sub-processor / supply-chain list (including model upstream)
5. Vendor attestation
The undersigned, on behalf of the vendor, attests that the disclosures above are true and complete to the best of their knowledge at the date signed, and undertakes to notify the buyer in writing within 30 days of any material change to those disclosures.
This is a sample form derived from the catalog at /wiki/china-genai-measures. Adapt before issuing. Not legal advice; not jurisdiction-specific. See charter §7.4.