Missing Value Chain in Generative AI Governance: China as an example

We examined the world's first regulation on generative AI, China's Provisional Administrative Measures of Generative Artificial Intelligence Services, which came into effect in August 2023. Our assessment reveals that these Measures, while recognizing the technical advances of generative AI and seeking to govern its full life-cycle, present unclear distinctions regarding different roles in the value chain of generative AI including upstream foundational model providers and downstream deployers. The lack of distinction and clear legal status between different players in the AI value chain can have profound consequences. It can lead to ambiguity in accountability, potentially undermining the governance and overall success of AI services.