You must regulate user-generated content: moderation mechanisms, reporting portals, and immediate takedown plus reporting of illegal material

Platforms are legally responsible for any issues arising from user content. You must set up a full system: user registration, post and comment moderation, daily monitoring, and clear procedures for handling incidents. Place a prominent reporting link on your site. When illegal content is found, immediately stop its distribution, document everything, and report it to authorities. Failure to do so can result in fines ranging from 50,000 to 500,000 yuan, with even harsher penalties for serious violations.

It costs money to hire moderators — this is the platform’s biggest ongoing expense. Reporting portals and records of every moderation action must be kept. The real challenge is that this work needs constant oversight; even a single day without it can lead to serious problems.

Regulations require platforms to “fulfill primary responsibility for managing user-generated content.” This means platforms must regulate everything users post. Specific requirements include establishing rules for registration, account management, post and comment moderation, page management, real-time monitoring, emergency response, and handling of misinformation and illegal networks. Every step — from registration and posting to daily checks and incident response — must be clearly documented. Platforms must also provide an easily accessible reporting link in a highly visible spot. Upon spotting illegal content, they must “immediately take necessary actions, preserve records, and report to authorities” as mandated by the Cybersecurity Law. Non-compliance brings warnings, mandatory corrections, and fines up to 500,000 yuan; repeat or severe violations can lead to fines up to 2 million yuan, suspension of operations, website or app shutdowns, or even revocation of business licenses. Individuals directly responsible may also face fines of 50,000–200,000 yuan nationwide.

You don’t need to invent moderation rules from scratch — just follow existing ones. Article 15 of the Internet Information Service Management Regulations explicitly lists nine categories of prohibited content. For live-streaming platforms, three extra obligations apply: they must set up a dedicated content moderation system, be able to instantly cut off any ongoing stream (“immediate blocking” per law), and retain both stream content and logs for at least 60 days. The same retention period applies to recorded online performances.

国家互联网信息办公室 (2019). 网络信息内容生态治理规定（网信办令第 5 号，第八、九、十、十六、三十七条）. http://www.cac.gov.cn/2019-12/20/c_1578375159509309.htm ; 全国人大常委会 (2025). 网络安全法（2025 年修正，2026 年 1 月 1 日施行，第四十九、六十九条）. https://www.cac.gov.cn/2025-12/29/c_1768735112911946.htm ; 国务院 (2000). 互联网信息服务管理办法（第十五、十六、二十三条）. https://www.gov.cn/gongbao/content/2011/content_1860864.htm