Regulatory Briefing | Key Duties Under Minors' Info Measures: Game Ecosystem Compliance

In January 2026, the Cyberspace Administration of China (CAC), together with multiple competent authorities, issued the Measures for the Classification of Online Information That May Affect Minors' Physical and Mental Health (the "Classification Measures"), which will take effect on March 1, 2026. The Classification Measures provide a clear delineation of the scope and typical manifestations of four categories of online information that may affect minors' physical and mental health. They also introduce risk-prevention requirements addressing content risks arising from the application of emerging technologies such as algorithmic recommendation and generative artificial intelligence, with the aim of offering clearer guidance to online platforms and content producers and strengthening the systematic protection of minors in the online environment.

Given that video game products inherently feature immersive interactive experiences, highly active UGC communities, and the deep integration of recommendation-driven distribution and GAI capabilities, the compliance impact of the Classification Measures is particularly significant for video game companies and the broader ecosystem. This article first examines the logic of information classification within China's online content governance framework to clarify the regulated entities and covered information types under the Classification Measures. It then focuses on how the Classification Measures' key obligations apply in typical video games scenarios, and further maps their linkage to higher-level laws and related regulations, including the corresponding enforcement pathways and potential legal consequences, so as to help companies build an implementable governance framework for minors-related risk information.

1. Information Classification in China's Online Content Ecosystem Governance and the Information Types Covered by the Classification Measures

China's online content ecosystem governance is not structured around a simple binary of "lawful vs. unlawful." Instead, it adopts a tiered approach based on the degree of potential harm and societal risk posed by information, and accordingly calibrates differentiated governance intensity and duty allocation. This approach encompasses not only support for positive content, but also the handling of unlawful content, as well as the prevention and guidance of information that has not risen to the level of illegality but nevertheless presents identifiable risks.

1.1 The Three-Tier Governance Structure Under the Governance Provisions

Under the Provisions on the Governance of the Online Information Content Ecosystem (the "Governance Provisions"), online content ecosystem governance takes online information content as its primary regulatory object and aims to foster a "clean" cyberspace through measures such as promoting positive energy and addressing illegal and undesirable information. Structurally, the Governance Provisions employ three distinct normative modalities—"encouraged", "prohibited", and "prevent and resist"—thereby forming a three-tier governance framework of encouraged (positive) content – prohibited (unlawful) content – prevent-and-resist (undesirable) content. The Governance Provisions further require platforms to refrain from disseminating unlawful information, to prevent and resist undesirable information, and to actively feature positive content while strengthening content-ecosystem management in key, high-exposure placements such as the homepage first screen, trending searches, rankings, and pop-up windows. In this way, classification is translated into operational governance intensity and concrete distribution scenarios.

1.2 Layered Minors-Protection Governance Under the Protection Regulation

From the perspective of minors' protection, the Regulation on the Online Protection of Minors (the "Protection Regulation") likewise does not rely solely on a binary of "unlawful vs. not unlawful." It extends the governance framework by introducing an additional tier of risk information that must be accompanied by notices and subject to restrictions. On the one hand, it prohibits the production, reproduction, publication, and dissemination of online information containing content such as obscenity and pornography, violence and terrorism, or inducement to self-harm or suicide, which may harm minors' physical and mental health. On the other hand, it establishes a risk tier of information that may affect minors' physical and mental health, requiring prominent notices prior to display, and authorizes the Cyberspace Administration of China (CAC), in conjunction with relevant authorities, to further specify the categories, scope, assessment criteria, and notice mechanisms for such information. The Protection Regulation also imposes scenario-based constraints—such as non-presentation in key sections, and correspondingly requires platforms to implement remedial measures including suspension of transmission, deletion, blocking, and link takedown.

1.3 Further Specification of the "Risk-Tier" Information Under the Classification Measures

Article 2 of the newly issued Measures for the Classification of Online Information That May Affect Minors' Physical and Mental Health (the "Classification Measures") provides that, "For the purposes of these Measures, 'online information that may affect minors' physical and mental health' refers to information disseminated via the Internet which, other than unlawful information containing content harmful to minors' physical and mental health as prescribed by laws and regulations, may trigger or induce minors to imitate unsafe behaviors, engage in conduct that violates social morality, develop extreme emotions, or form unhealthy habits, among other impacts." Article 7 further provides that, "With respect to such online information that may affect minors' physical and mental health, online information content producers and providers of online products and services shall, in accordance with the requirements set out in laws and regulations including the Provisions on the Governance of the Online Information Content Ecosystem (the 'Governance Provisions') and the Provisions on the Governance of Cyberbullying Information, take prevent-and-resist measures to avoid adverse impacts on minors' physical and mental health."

Accordingly, at the structural level, the Classification Measures clearly confine their scope to the "risk tier" within the minors-protection context, and, at the level of governance requirements, align with and operationalize the "prevent and resist" approach mandated under the Governance Provisions.

Building on this positioning, the Classification Measures further break down this risk-tier information into practicable and operational categories, specifically comprising the following four types:

1.3.1 Online Information That May Trigger or Induce Minors to Imitate or Engage in Undesirable Conduct

Under the Classification Measures, such information includes, without limitation:

• content containing sexual insinuation or sexual provocation that is likely to evoke sexual associations;
• undesirable information involving cyberbullying, such as accusation, mockery, disparagement, or discrimination;
• content that incites group-based discrimination, regional discrimination, or confrontation and conflict;
• content that, through deliberate stimulation or malicious inducement, causes minors to experience excessively intense or persistent extreme emotions such as anger, fear, or depression;
• content showing dangerous acts such as unsafe driving, inducing imitation of high-risk behaviors, entry into dangerous areas, or other acts that may impair physical health;
• content that disseminates undesirable online slang through means such as homophonic puns, abbreviations, character splitting, or combined text-and-image formats;
• content that promotes unhealthy lifestyles among minors, such as smoking (including e-cigarettes), drinking alcohol, binge eating, tattooing, or unreasonable use or abuse of drugs;
• content that promotes conduct in violation of school rules and discipline, such as ghostwriting, copying on behalf of others, plagiarism and cheating, truancy, skipping classes, or bullying of students;
• content that induces minors to blindly idolize celebrities or participate in irrational and extreme "fan-circle" behavior;
• content that induces minors to engage in irrational spending, such as top-ups/recharges or tipping/rewarding;
• content that teaches minors to make harmful "creative" handicrafts;
• content that provides to, or seeks from, minors services such as paid play companionship / chat companionship, or power-leveling / boosting / account piloting; and
• other information that may trigger or induce minors to imitate or engage in undesirable conduct.

1.3.2 Online Information That May Negatively Affect Minors' Values

Under the Classification Measures, such information includes, without limitation:

• content that promotes notions such as disregard for life or self-deprecation;
• content that promotes undesirable values such as extravagant hedonism, ostentatious wealth display and money worship, or negativity and decadence;
• content that promotes distorted aesthetic standards or vulgar / lowbrow culture;
• content that promotes pseudoscience through absurd or bizarre narratives or alarmist claims;
• content that promotes unhealthy views on friendship or romantic relationships;
• content that promotes ideas such as "studying is useless," "scores are everything," or "advancement to higher schools is the only goal"; and
• other content that promotes value orientations contrary to public order and good morals and social morality.

1.3.3 Online Information Involving Improper Use of Minors' Images

Under the Classification Measures, such information includes, without limitation:

• content that uses minors' images in staged filming or dramatized performances to present plot content containing undesirable values or inappropriate words or conduct;
• content that uses minors' images to display or market products and services not suitable for minors;
• content that uses minors' voices to disseminate undesirable content;
• content that seeks attention by mocking minors or creating a controversial persona by exploiting minors;
• content that uses minors in short videos for prolonged staged filming to accumulate popularity and seek profit;
• content that conducts tests of minors' conduct or morality in an inappropriate manner or for improper purposes;
• content that distorts or sensationalizes minors-related illegal or criminal conduct; and
• other improper disclosure and use of minors' images.

1.3.4 Online Information Involving Improper Disclosure or Use of Minors' Personal Information

Under the Classification Measures, such information includes, without limitation:

• content that, without the guardian's consent, improperly displays information relating to the study or daily life of minors under the age of fourteen in a manner that may expose minors' personal information;
• content that induces minors to publish information that may disclose their own or others' personal information; and
• other improper disclosure and use of minors' personal information.

2. Key Obligations Under the Classification Measures and Their Application in the Video Game Ecosystem

The Classification Measures do not contain a standalone provision defining "scope of application." Instead, they define the regulated scope indirectly by enumerating the obligated entities, thereby covering, in general, (i) organizations and individuals that produce, reproduce, publish, or disseminate online information content, and (ii) platform-type entities that provide online products and services. The Measures also bring within their regulatory ambit entities that provide technical services such as algorithmic recommendation and generative artificial intelligence, and they further place particular emphasis on entities associated with online products and services specifically oriented toward minors. Mapped onto the video game ecosystem, the regulated entities include not only video game companies that create and externally disseminate content throughout the stages of development, publishing, and operations, but also video game community platforms that host content display and distribution, as well as providers of recommendation/distribution and GAI technologies. In addition, creators and publishers of UGC—including players, streamers, KOLs, and MCNs—may also fall within the regulatory scope of the Classification Measures when their activities involve the relevant categories of information.

Correspondingly, under China's current framework for minors' online protection, governance requirements for "online information that may affect minors' physical and mental health" can be summarized as a progressive three-tier compliance structure. The first tier is Clear and Conspicuous Notice, requiring that relevant risk information carry a clear risk warning prior to display and in a conspicuous position, with platforms providing notice-labeling functionality and prompting labeling—or, where required by law, restricting transmission—when notice is absent. The second tier is Restriction on Prominent Placement of Risk Information, under which providers of online products and services must not present such information in high-exposure placements such as the homepage first screen, pop-up windows, trending searches, rankings, recommendations, and featured selections, so as to prevent amplification and exposure driven by traffic mechanisms. The third tier is a stricter "no-push / no-access" regime applicable to specific entities and scenarios: on the one hand, it imposes stronger technical constraints on automated distribution mechanisms such as algorithmic recommendation and GAI, prohibiting the pushing of such information to minors; on the other hand, it requires that such information not be produced, reproduced, published, or disseminated in online products and services specifically oriented toward minors.

2.1 Clear and Conspicuous Notice Requirement

Pursuant to Articles 8(1) and 8(2) of the Classification Measures, "with respect to online information that may affect minors' physical and mental health, organizations and individuals that produce, reproduce, publish, or disseminate such information shall, in accordance with the Protection Regulation, provide a clear and conspicuous notice in a conspicuous position prior to the display of the information. Providers of online products and services shall provide users with labeling functionality capable of creating a clear-and-conspicuous-notice effect, and shall guide and regulate users in providing notices for relevant information." The core of this requirement is to ensure that, before the relevant risk information reaches users, the risk is communicated in a conspicuous and readily identifiable manner, thereby reducing minors' inadvertent exposure to such information and mitigating the risk of amplified reach driven by traffic mechanisms.

Article 8 of the Classification Measures enumerates notice methods by content form and service scenario, covering text, audio, images, video, virtual scenes, and other adaptable approaches, as follows:

• for text, adding a written notice or a generally recognized symbol notice at an appropriate position at the beginning, end, or middle of the text, or adding a clear and conspicuous notice label on the interactive interface or around the text;
• for audio, adding a voice notice or an audio-rhythm notice at an appropriate position at the beginning, end, or middle of the audio, or adding a clear and conspicuous notice label on the interactive interface;
• for images, adding a clear and conspicuous notice label at an appropriate position on the image or on the interactive interface;
• for video, adding a clear and conspicuous notice label at an appropriate position on the initial frame and around the video playback area; where appropriate, adding clear and conspicuous notice labels at the end of the video and at an appropriate position in the middle of the video, or adding a clear and conspicuous notice label on the interactive interface;
• for virtual scenes, when presenting a virtual scene, adding a clear and conspicuous notice label at an appropriate position on the initial screen; where appropriate, adding clear and conspicuous notice labels at an appropriate position during the continuous provision of the virtual-scene service; and
• other clear and conspicuous notice-labeling methods suited to the characteristics of the relevant service scenario.

Video game operators, providers of UGC functionalities such as in-game communities or workshops, entities responsible for video game publishing and promotion and for producing and disseminating advertising materials, as well as UGC creators and content publishers such as players and streamers/video creators, should all pay close attention to compliance exposure under Article 8 of the Classification Measures. In particular, they should verify whether notices are truly provided prior to display and in conspicuous positions, and whether notice methods are properly adapted to different content forms, including text, audio, images, video, and virtual scenes. Special care should be taken to assess whether the following scenarios involve risk information and, if so, whether the required notice labeling and related user guidance and governance measures have been properly implemented, including:

• Text: version announcements, event pages, community posts, global chat/private chat, user signatures/nicknames, etc.;
• Audio: voice-room titles and interaction pages, voice UGC, and in-video game voice content;
• Images: character illustrations, posters, screenshot UGC, workshop-item cover images, etc.;
• Video: promotional videos (PV), CG, replays, short-video UGC, livestream replays, etc.; and
• Virtual scenes: loading pages and key interaction entry points when entering a gameplay mode, room, map, or event dungeon/instance, etc.

2.2 Restriction on Prominent Placement of Risk Information

Article 9(1) of the Classification Measures provides that "providers of online products and services shall implement the requirements of the Protection Regulation and must not display online information that may affect minors' physical and mental health in prominent, attention-grabbing key placements such as the homepage first screen, pop-up windows, trending searches, rankings, recommendations, and featured selections." The core objective of this obligation is to prevent risk information from being delivered to users by default and from being aggregated and amplified by traffic mechanisms. Unlike the clear and conspicuous notice requirement—which assumes the information may be displayed provided that risks are communicated clearly before display—the restriction on prominent placement emphasizes that, even where the content does not constitute unlawful information, risk information must not occupy high-exposure placements.

Video game operators and video game community service providers should pay attention to compliance risks under this requirement, because key placements typically extend well beyond an official website homepage and include any default display surfaces that are high-exposure and strongly steering. Key placements in the video game context may include, for example:

• Homepage first screen: splash/start screen, main lobby, the first screen of an events hub, the first screen of a community homepage, and default channels (e.g., "Recommended" or "Discover" pages).
• Pop-up windows: post-login pop-ups, event pop-ups, promotional pop-ups, and forced announcement pop-ups.
• Trending searches or rankings: default "hot keywords" in the search box, trending-search lists, trending-post lists, popular-creation rankings, popular-streamer rankings, and topic leaderboards.
• Recommendations or featured selections: "For You" / "You May Like" feeds, automated recommendation slots, editor's picks, pinned placements, banner placements, and push-notification recommendations.

Beyond the scenarios above, any placement that users can see without actively searching, or any location where the system steers users to click through, may also be regarded as a prominent, attention-grabbing key placement.

2.3 Prohibition on Recommending Risk Information to Minors via Algorithmic Recommendation and Generative AI

Pursuant to Article 9(2) of the Classification Measures, entities that provide services such as algorithmic recommendation and generative artificial intelligence (GAI) shall establish and improve sound safety management systems and technical measures, and must not recommend or otherwise push to minors any online information that may affect their physical and mental health. This provision shifts the regulatory focus further upstream—from whether such content exists to how it reaches minors through distribution pathways—and emphasizes the need to block, through both institutional controls and technical safeguards, minors' exposure via proactive pushes, personalized recommendation, automated delivery, or AI-generated outputs.

Video game operators, providers of UGC functionalities such as in-video game communities or workshops, video game publishing platforms and co-publishing/distribution partners, as well as third-party technology service providers that supply video games with recommendation, ad delivery, content review, or GAI capabilities, should all pay attention to and implement the compliance requirements under Article 9(2) of the Classification Measures: establishing appropriate safety management systems and technical measures, and ensuring that risk information is not recommended or pushed to minors. The core of this obligation is not whether a notice is provided; rather, it is whether recommendations, pushes, automated delivery, and personalized distribution to minor users are effectively blocked. In particular, controls should cover high-impact distribution pathways such as default exposure, algorithmic ranking amplification, intelligent delivery through operational placements, and delivery through in-app messages and push notifications.

In video game scenarios, special attention should be given to the following touchpoints involving algorithmic recommendation, automated delivery, and GAI outputs, to determine whether risk information is being recommended or pushed to minors:

• Algorithmic recommendation and ranking: community/workshop recommendation feeds, "For You" feeds, leaderboard/popularity rankings, default search hot keywords and auto-suggestions, and similar features. The compliance focus is to implement filtering and blocking controls on the minors-facing side, preventing risk information from being amplified and delivered to minors by algorithms.
• Operational placements and commercial ad delivery: event hub first screens, banner placements, pinned/featured placements, personalized bundles/offers, and targeted advertising. Based on age verification and user segmentation strategies, video game services should enforce minors-invisible/minors-inaccessible constraints for display and ad serving.
• System messages and pop-up delivery: in-app notifications, in-game mail, pop-ups, and push-notification re-engagement campaigns. The prohibition should be hard-coded into sending rules and audience-targeting logic to prevent messaging channels from becoming a workaround. Where GAI interaction or content-generation capabilities are introduced, services should also implement minors-facing output filters, refusal responses, and safety policies, to prevent "generated content" from becoming an indirect form of recommendation or push.

2.4 Strict Prohibition (Must-Not-Include) Requirement for Risk Information in Minor-Directed Video Game Products and Dedicated Zones

Pursuant to Article 9(3) of the Classification Measures, "no organization or individual shall, in online products and services specifically oriented toward minors, produce, reproduce, publish, or disseminate online information that may affect minors' physical and mental health." This requirement reflects a "zero-presence" governance objective for minor-directed contexts: once a product or service is positioned as specifically oriented toward minors, risk information should no longer be handled through approaches such as "display with a clear and conspicuous notice" or "reduced exposure by avoiding prominent placements." Instead, it should be treated as prohibited for entry into that context, and blocked end to end—from content creation, submission and release review, and content-library management to display and distribution.

For video game operators and their minor-directed products and dedicated zones (e.g., a kids version, a minors-only community, a dedicated content pool under a kids mode, or educational/interactive gameplay zones specifically oriented toward minors), the "zero-presence" rule imposes materially higher compliance requirements than the clear and conspicuous notice requirement or the restriction on prominent placement. Once the relevant product/service or functional zone is positioned as specifically oriented toward minors, for "online information that may affect minors' physical and mental health" under the Classification Measures, it should not be addressed through "notice-plus-display," "downranking/reduced exposure," or "keeping it out of key entry points." Rather, a strict prohibition approach should be adopted, with blocking mechanisms embedded throughout the full chain—including content production, submission and release review, content-library management, display and distribution, and interactive dissemination—to ensure that such information is not produced, reproduced, published, or disseminated within minor-directed video game contexts.

3. Alignment Between the Key Obligations Under the Classification Measures and Other Laws and Regulations, and the Legal Consequences for Non-Compliance

The Classification Measures do not themselves contain standalone, detailed penalty provisions. However, Article 10 provides that "where these Measures are violated, the matter shall be handled in accordance with the provisions of laws and administrative regulations such as the Cybersecurity Law of the People's Republic of China and the Protection Regulation." Accordingly, the Classification Measures function primarily to further specify "online information that may affect minors' physical and mental health" into identifiable and implementable compliance standards. As a matter of enforcement and sanctions, the legal basis for regulatory measures and penalties will, in principle, be traced back to the obligation and liability provisions under higher-level laws and regulations, including the Cybersecurity Law and other relevant rules.

3.1 Alignment with the General Provisions of the Cybersecurity Law and the Corresponding Legal Consequences

In its general provisions, the Cybersecurity Law emphasizes that the State supports online products and services that are conducive to minors' healthy development and punishes activities that use the Internet to harm minors' physical and mental health. It further requires network operators, when carrying out business and service activities, to comply with laws and administrative regulations, fulfill cybersecurity protection obligations, and accept supervision.

From the perspective of the content-governance linkage, Article 49 of the Cybersecurity Law requires network operators to strengthen the management of information published by their users. Where information prohibited from being published or transmitted under laws or administrative regulations is discovered, the operator must immediately stop transmission, take measures such as removal to prevent further dissemination, retain relevant records, and report to the competent authorities. Article 52 further empowers the cyberspace administration authorities and other competent authorities, when performing supervision and administration duties, to issue regulatory orders requiring network operators to stop transmission and dispose of such prohibited content and to retain relevant records.

Accordingly, where "online information that may affect minors' physical and mental health" under the Classification Measures, in a specific case, also falls within content forms that are prohibited from being published or transmitted under other laws or administrative regulations, the competent regulators may invoke the handling mechanism under the Cybersecurity Law. Where a network operator fails to fulfill the stop-transmission/disposal and record-retention/reporting obligations under Article 49, or fails to comply with regulatory orders issued under Article 52, it may directly fall within the penalty scope of Article 69. Under that provision, the competent authorities may order rectification, issue a warning, and circulate a notice of criticism, and may impose a fine ranging from RMB50,000 to RMB 500,000. Where the operator refuses to rectify or the circumstances are serious, a fine ranging from RMB 500,000 to RMB 2,000,000 may be imposed, and the authorities may order suspension of the relevant business, business rectification, closure of the website or application, revocation of the relevant business permit, or revocation of the business license; additionally, the directly responsible person in charge and other directly responsible personnel may be fined from RMB 50,000 to RMB 200,000. Where particularly serious impacts or consequences are caused, a fine ranging from RMB 2,000,000 to RMB 10,000,000 may be imposed, together with the same types of administrative measures (including suspension of business, rectification, closure, and license revocation), and the directly responsible person in charge and other directly responsible personnel may be fined from RMB 200,000 to RMB 1,000,000.

In addition, where the risk categories covered by the Classification Measures involve scenarios such as "improper disclosure or use of minors' personal information," the Classification Measures may also be linked to the Cybersecurity Law's general personal information obligations. These include, among others, the foundational requirements in Articles 43 through 45 concerning the lawful, proper, and necessary collection and use of personal information; explicit notice and consent; prohibitions on leakage, tampering, or destruction; adoption of security measures and breach-related remedial notification and reporting; and rights to deletion and correction. In terms of legal consequences, Article 71(2) clarifies that violations of Articles 43 through 45 and other provisions that infringe personal information rights and interests shall be handled and penalized "in accordance with the relevant laws and administrative regulations," and in practice this often further links to specialized legislation such as the Personal Information Protection Law.

3.2 Alignment Between the Four Key Obligations Under the Classification Measures and Other Laws and Regulations, and the Legal Consequences for Non-Compliance

3.2.1 Clear and Conspicuous Notice Requirement

From the perspective of linkage with related laws and regulations, the Clear and Conspicuous Notice Requirement was first established under the Law on the Protection of Minors. Article 51 requires that online information containing content that may affect minors' physical and mental health be accompanied by a notice in a prominent manner. Article 80 further provides that where a platform discovers that a user has published or disseminated such information without providing the required prominent notice, the platform shall prompt the user to provide the notice or notify the user to provide the notice; where the notice is not provided, the information must not be transmitted. Building on this framework, Article 23 of the Protection Regulation expressly requires a clear and conspicuous notice prior to display for such information within online products and services, and establishes corresponding platform-side linkage provisions through Article 29(2) and Article 30: where the platform discovers that the required notice has not been provided, it shall prompt or notify notice-labeling; and where the notice is not provided, the information must not be transmitted.

With respect to legal consequences for violating the Clear and Conspicuous Notice Requirement, the Law on the Protection of Minors and the Protection Regulation provide two enforcement pathways:

(1) Platform regulatory handling under the Protection Regulation

Where competent authorities discover that information covered by Article 23(1) of the Protection Regulation is not accompanied by the required clear and conspicuous notice, they may, pursuant to Article 30 of the Protection Regulation, require the provider of online products and services to handle the matter in accordance with Article 29(2), namely: provide the notice or prompt/notify the user to provide the notice; where the notice is not provided, the information must not be transmitted.

(2) Administrative penalties under the Law on the Protection of Minors

Different liability provisions may apply depending on the violating party and the nature of the conduct. First, where an entity that publishes or disseminates content fails to fulfill the notice obligation under Article 51, the competent authority may, pursuant to Article 121, order rectification within a prescribed time limit, issue a warning, confiscate unlawful gains, and may additionally impose a fine of up to RMB 100,000. Where the party refuses to rectify or the circumstances are serious, the authority may order suspension of relevant business, suspension of production and business operations, or revocation of the business license and/or relevant permits; where unlawful gains exceed RMB 1,000,000, a fine of one to ten times the unlawful gains may be imposed; where there are no unlawful gains or the unlawful gains are less than RMB 1,000,000, a fine ranging from RMB 100,000 to RMB 1,000,000 may be imposed. Second, where a network service provider, after discovering that a user has published or disseminated such information without the required notice, fails to perform the prompting/notification obligation under Article 80, or fails to take measures such as deletion, blocking, or link takedown with respect to information that still lacks the required notice, the competent authority may, pursuant to Article 127, order rectification, issue a warning, and confiscate unlawful gains; where unlawful gains exceed RMB 1,000,000, a fine of one to ten times the unlawful gains may be imposed; where there are no unlawful gains or the unlawful gains are less than RMB 1,000,000, a fine ranging from RMB 100,000 to RMB 1,000,000 may be imposed; additionally, the directly responsible person in charge and other responsible personnel may be fined from RMB 10,000 to RMB 100,000. Where the party refuses to rectify or the circumstances are serious, the authority may also order suspension of relevant business, business rectification, closure of the website, or revocation of the business license and/or relevant permits.

3.2.2 Restriction on Prominent Placement of Risk Information

The Restriction on Prominent Placement of Risk Information directly aligns with Article 24(2) of the Protection Regulation, which provides that providers of online products and services must not display, in prominent and attention-grabbing key placements such as the homepage first screen, pop-up windows, and trending searches, the information described in Article 23(1) of the Protection Regulation that may affect minors' physical and mental health. On this basis, Article 9 of the Classification Measures, within the framework of implementing the Protection Regulation, further specifies typical forms of "key placements," expressly incorporating common high-exposure entry points such as rankings, recommendations, and featured selections. This transforms "key placements" from a principle-based concept into an operational placement list, enhancing the practicability of compliance requirements.

From the perspective of general online content ecosystem governance, Article 11 of the Governance Provisions establishes a similar key-placement control framework: online information content service platforms must not present, in key placements such as the homepage first screen, pop-up windows, trending searches, rankings, recommendations, and featured selections, the "undesirable information" listed in Article 7 of the Governance Provisions, which includes content types closely associated with minors' protection, such as inducing minors to imitate unsafe behaviors or inducing unhealthy habits. From the perspective of regulating online platforms for specific service sectors, Article 11(1)(8) further specifies that, for digital reading, online video game, and online animation services, placements such as the homepage first screen, featured selections, rankings, and pop-up windows constitute key placements.

With respect to legal consequences for violating the Restriction on Prominent Placement of Risk Information, two enforcement pathways apply:

(1) Handling measures and administrative penalties under the Protection Regulation

Where competent authorities discover information that violates Article 24, they may, pursuant to Article 30 of the Protection Regulation, require the platform to, in accordance with Article 29, immediately stop transmission of the relevant information, take measures such as deletion, blocking, or link takedown to prevent further dissemination, retain relevant records, and report to authorities such as the Cyberspace Administration authorities and public security authorities. The platform may also be required to take measures against users who produce, reproduce, publish, or disseminate such information, including warnings, function restrictions, service suspension, or account closure.

In terms of administrative penalties, Article 55 of the Protection Regulation provides specific legal consequences for "violations of Article 24." Competent authorities—including those responsible for cyberspace administration, news and publishing, film, telecommunications, public security, culture and tourism, market regulation, and broadcasting and television—may, within their respective mandates, order rectification within a prescribed time limit, issue a warning, confiscate unlawful gains, and may additionally impose a fine of up to RMB 100,000. Where the party refuses to rectify or the circumstances are serious, the authority may order suspension of relevant business, suspension of production and business operations, or revocation of the relevant business permit and/or business license; where unlawful gains exceed RMB 1,000,000, a fine of one to ten times the unlawful gains may be imposed; where there are no unlawful gains or the unlawful gains are less than RMB 1,000,000, a fine ranging from RMB 100,000 to RMB 1,000,000 may be imposed.

In addition, the Protection Regulation provides a specific administrative penalty mechanism for platforms. Where a platform fails to establish and implement the management and handling mechanisms required under Article 29(1), or passively fails to implement a competent authority's handling requirements issued under Article 30 (i.e., to handle matters in accordance with Article 29), such conduct may, in addition to being deemed a violation of Article 24, also be evaluated as a violation of Article 29(1), thereby triggering Article 56 of the Protection Regulation. Under Article 56, competent authorities (including those responsible for cyberspace administration, news and publishing, film, education, telecommunications, public security, culture and tourism, and broadcasting and television) may, within their respective mandates, order rectification, issue a warning, and confiscate unlawful gains; where unlawful gains exceed RMB 1,000,000, a fine of one to ten times the unlawful gains may be imposed; where there are no unlawful gains or the unlawful gains are less than RMB 1,000,000, a fine ranging from RMB 100,000 to RMB 1,000,000 may be imposed; additionally, the directly responsible person in charge and other directly responsible personnel may be fined from RMB 10,000 to RMB 100,000. Where the party refuses to rectify or the circumstances are serious, the authority may also order suspension of relevant business, business rectification, closure of the website, or revocation of the relevant business permit and/or business license.

(2) Regulatory measures and administrative consequences under the Governance Provisions

Where "undesirable information" listed in Article 7 of the Governance Provisions is presented in key placements listed in Article 11, this may trigger Article 36 of the Governance Provisions. Under Article 36, cyberspace administration authorities at or above the municipal level with districts may, within their authority, conduct a regulatory interview, issue a warning, and order rectification within a prescribed time limit; where the party refuses to rectify or the circumstances are serious, the authority may order suspension of information updates and handle the matter in accordance with relevant laws and administrative regulations.

3.2.3 Prohibition on Recommending Risk Information to Minors via Algorithmic Recommendation and Generative AI

From the perspective of linkage with related laws and regulations, the higher-level baseline rule first derives from Article 25 of the Protection Regulation. Addressed to "any organization or individual," it broadly prohibits sending or pushing, or luring or coercing minors to access, online information containing content that is harmful to minors or that may affect minors' physical and mental health, thereby establishing a general bottom line for "no-push." At the level of algorithm-specific governance, Article 18 of the Provisions on the Administration of Algorithmic Recommendation in Internet Information Services (the "Recommendation Management Provisions") further specifies minors-protection obligations for algorithmic recommendation service providers, expressly prohibiting the pushing to minors of information that may affect minors' physical and mental health—such as content that may trigger imitation of unsafe behaviors, conduct that violates social morality, or unhealthy habits—and prohibiting the use of algorithms to induce minors' internet addiction. At the level of generative artificial intelligence governance, Article 10 of the Interim Measures for the Management of Generative Artificial Intelligence Services (the "GAI Service Interim Measures") requires service providers to take effective measures to prevent minor users from excessive reliance or addiction. On this basis, Article 9(2) of the Classification Measures extends the "no-push" requirement to both algorithmic recommendation and generative AI service modalities, uniformly requiring that risk information within the scope of "online information that may affect minors' physical and mental health" not be recommended or pushed to minors through either of these service types.

With respect to legal consequences for violating the Prohibition on Recommending Risk Information to Minors via Algorithmic Recommendation and Generative AI, three enforcement pathways apply:

(1) Handling measures and administrative penalties under the Protection Regulation

As with the framework described above, violations of the "no-push" obligation under Article 25 of the Protection Regulation are subject to the handling mechanism under Article 29 and the corresponding administrative penalty provisions.

(2) Liability linkage under the Recommendation Management Provisions

Where the violating party is an algorithmic recommendation service provider that breaches the minors-protection and "no-push" obligations under Article 18 of the Recommendation Management Provisions, Article 32 provides that the cyberspace administration authorities, together with relevant authorities such as telecommunications, public security, and market regulation authorities, shall handle the matter in accordance with their respective mandates. Through this liability-linkage design, algorithmic recommendation service providers are clearly brought within the scope of supervisory enforcement and sanctioning, providing a direct regulatory interface for unlawful conduct in the distribution chain involving the recommendation/pushing of minors-related risk information. Where the conduct involves sending or pushing to minors information containing content that is harmful or that may affect minors' physical and mental health, enforcement in practice may further link to the administrative penalty rules under Article 25 and Article 55 of the Protection Regulation.

(3) Liability linkage under the GAI Service Interim Measures

Where the violating party is a generative AI service provider that breaches relevant obligations under the GAI Service Interim Measures, Article 21 provides that competent authorities shall prioritize penalties under laws and administrative regulations such as the Cybersecurity Law, the Data Security Law, the Personal Information Protection Law, and the Science and Technology Progress Law. Where no relevant law or administrative regulation provides otherwise, competent authorities may, within their mandates, issue a warning, circulate a notice of criticism, and order rectification within a prescribed time limit; where the party refuses to rectify or the circumstances are serious, the authority may order suspension of the provision of the relevant services. Through this "higher-level laws first plus regulatory fallback" liability-linkage mechanism, generative AI service providers are clearly brought within the scope of supervisory inspections and enforcement by cyberspace administration authorities and other competent regulators, thereby providing an enforceable interface for violations occurring across content generation, interactive output, and service operation chains.

3.2.4 Alignment and Consequences for the Strict Prohibition (Must-Not-Include) Requirement for Risk Information in Minor-Directed Products and Dedicated Zones

This "zero-presence" obligation for minor-directed contexts directly aligns with Article 24(1) of the Protection Regulation, which expressly provides that no organization or individual shall, in online products and services specifically oriented toward minors, produce, reproduce, publish, or disseminate the "online information that may affect minors' physical and mental health" as referred to in Article 23(1) of the Protection Regulation. Within the framework of implementing the Protection Regulation, Article 9(3) of the Classification Measures further strengthens an operationally implementable "prohibited content scope" by referencing the more detailed categories of risk information and assessment standards specified under the Classification Measures. In addition, from the perspective of general online content ecosystem governance, Article 11(12) of the Governance Provisions also brings "information content columns, dedicated zones, products, and similar offerings specifically oriented toward minors" within the scope of key placements, and requires that such placements must not present the "undesirable information" listed in Article 7, thereby imposing stricter requirements from the standpoint of platform content ecosystem governance for minor-directed dedicated zones and products.

With respect to legal consequences for violating the Strict Prohibition (Must-Not-Include) Requirement for Risk Information in Minor-Directed Video Game Products and Dedicated Zones, two enforcement pathways apply:

(1) Handling measures and administrative penalties under the Protection Regulation

As with the framework described above, violations of the prohibition under Article 24(1) of the Protection Regulation are subject to the handling mechanism under Article 29 and the corresponding administrative penalty provisions.

(2) Regulatory measures and administrative consequences under the Governance Provisions

Similarly, where "undesirable information" listed in Article 7 of the Governance Provisions is presented in minors' dedicated zones or products referred to in Article 11(12), this likewise falls within the scope of Article 36 of the Governance Provisions, together with the corresponding regulatory measures and administrative consequences.

Overall, within the existing tiered governance framework for minors-related risk information, the Classification Measures push minors' online protection into a more refined and operational stage, transforming "risk information" from an abstract compliance judgment into implementable labeling rules and distribution-control rules. For video game companies and developers, this means that compliance can no longer be confined to content review alone; instead, the "risk-information classification standards" should be embedded across the end-to-end chain—including R&D, operations, community governance, monetization and ad delivery, algorithmic recommendation, and generative artificial intelligence (GAI) outputs. In practice, this entails implementing the Clear and Conspicuous Notice requirement in scenarios where display is permitted; strictly enforcing the Restriction on Prominent Placement of Risk Information at high-exposure entry points; applying the Prohibition on Recommending Risk Information to Minors via Algorithmic Recommendation and Generative AI to minors-facing recommendation and generation-driven delivery touchpoints; and treating zero presence as the baseline requirement for minor-directed products and dedicated zones.

Annex: Linkage Table Between the Four Key Obligations Under the Classification Measures and Other Laws and Regulations