Following the summit of President Trump and Chines…
Following the summit of President Trump and Chinese leader Xi Jinping in mid-May, the two sides announced that they would start a government-to-government dialogue on artificial intelligence (AI).
Agreeing to start a dialogue is a significant step, but it raises as many questions as it answers. Is productive US-China dialogue on AI even possible? (I think it is, if you come at it right.) If so, what should the countries discuss? (Open question, I lean toward best practices in testing models for mutual threats that cross borders.) Who should the U.S. try to engage with in China on AI?
In this piece, I’ll try to answer that third question. There’s lots of uncertainty here and I’ll do my best to account for parts of it by outlining the strengths and weaknesses of different Chinese interlocutors across different potential dialogue topics.
This piece will have three sections:
I. Executive Summary / TLDR: Who should the U.S. talk to in China on different aspects of AI?
II. Mapping China’s AI Bureaucracy: Colorful charts of the whole apparatus.
III. Strengths and Weaknesses of Different Actors in China: More in the weeds breakdown on who does what, and why certain orgs are best to talk to on certain topics.
I’ve also taken all the images and org charts from throughout the piece and turned them **into this shareable Google Slides Deck ** . You can get the same effect by simply scrolling through this piece and checking out each of the charts.
Before beginning, three important caveats. First, the internal politics and bureaucratic / personal turf wars are really hard to understand from the outside, and so parts of this should be seen as (informed) speculation. Second, I’ve never been a U.S. diplomat or arranged governmental (Track I) dialogues, so I’m sure that I’m missing many key dynamics. I view figuring all this stuff out as a team sport, and I really welcome reader feedback on these previous two things.
Finally, the U.S. doesn’t simply get to pick it’s counterparts or independently decide the agenda for the dialogue. These will all be part of a negotiation with the Chinese side, including who they want to talk to from the U.S. government.
One final note that shapes my thinking on all this: I believe that (at least for now) the most important actions on AI governance and safety will be domestic actions that the U.S. and China take — not international or bilateral agreements. There may be some level of light touch coordination, but it’s unlikely to be “We do X because you’ve promised to do it too.” That said, I think engagement between the two countries can really matter, both for communicating about emerging risks/responses and for sharing certain safety-enhancing practices (such as approaches to testing and evaluation).
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Let’s begin. Any dialogue will include a delegation of representatives from different organizations on both sides, with one or two of those designated as the leads in the delegation. With that in mind…
Given that it appears Secretary Bessent is leading on the U.S. side, his most logical counterpart is He Lifeng , Politburo member, lead on U.S.-China economic issues, frequent Bessent counterpart, and former head of the NDRC (see below).
For a conversation on **mandatory testing, evaluation, and standards for frontier AI models, ** the best counterpart would be the Cyberspace Administration of China (CAC) and its subordinate organizations .
For a broad conversation on AI policy —including both development and big picture governance—the best counterpart would be the National Development and Reform Commission (NDRC).
The NDRC would also make for a logical lead of the delegation given its role in coordinating AI policy across the government (more detail below) and its strong ties to He Lifeng.
For a conversation on the scientific trajectory of AI and long-term impacts , the best counterpart would be the Ministry of Science and Technology .
For a conversation on real-world applications and related industry standards , the best counterpart would be the Ministry of Industry and Information Technology (MIIT) .
For a conversation on international or multilateral AI governance the best counterpart would be the **Ministry of Foreign Affairs (MFA) ** and the related CCP commission that, the Central Foreign Affairs Committee (CFAC) .
If the NDRC isn’t the lead of the Chinese delegation, it would likely be the MFA’s Department of Arms Control, which has been given the role of coordinating AI affairs across the ministry.
Putting this together, into a potential configuration for the Chinese side.
Note on the Ministry of Finance as a potential co-lead of the delegation: MOF Vice Minister Liao Min was reportedly involved in talks with Secretary Bessent to set up the dialogue before the Beijing summit. MOF has little direct involvement in AI policy, but maybe this early role (and the Finance<>Treasury parallels) means they will retain a coordinating role.
Aside from Secretary Bessent’s likely role as the delegation lead, I won’t speculate on the configuration or roles and responsibilities of the U.S. side. Those respective roles seem to be very much up in the air and I’ll leave that reporting and analysis to others. I imagine someone in China is writing the inverse version of this piece analyzing potential U.S. counterparts…
For reference, these were the delegations at the 2024 US-China AI dialogue, with the Chinese participants in the order listed in their readout:
**China: ** MFA (delegation lead, North America Dept), MOST, NDRC, CAC, MIIT, Central Foreign Affairs Commission。
**US: ** NSC, State, Commerce (I believe that’s it).
Ok, before diving deeper into the bureaucracy and strengths/weaknesses of each organization, it’s worth getting a little more detail on who does what in Chinese AI policy — I’ll expand on these below.
**The CAC — The Regulator. ** The CAC is China’s primary internet and data regulator, and has been the lead author and enforcer of China’s binding regulations on AI. It has regulated recommendation algorithms, deepfakes, generative AI, labeling requirements for AI-generated content, and more. Orgs under CAC — particularly the standards group TC260 and CNCERT — are critical players in the nuts and bolts of regulatory compliance, risk management, and related standards.
**The NDRC - The Coordinator. ** The NDRC’s core role is as a macro-economic planner. It previously had a limited role in AI policy, but after the debut of ChatGPT the top leadership gave it the role of coordinating AI policy across the different ministries. That coordination role wasn’t made public, and the mechanisms and effectiveness of this coordination aren’t clear. The NDRC has the lead role in implementing China’s AI+ (re: AI diffusion) plan , and also plays a critical role in compute and data issues.
MOST — The Big (Scientific) Picture. MOST played a major role in China’s early AI development plans, and led on some “soft law” approaches to AI governance. After a 2023 re-org, it became the office of new CCP Central Commission on Science and Technology, sharpening its focus on strategic planning and reform of the S&T system. People there now describe it as “the OSTP of China.”
MIIT — Tech Support. MIIT leads on industrial (broadly defined) applications of AI. It’s a co-signatory on the CAC’s AI regulations and does lots of the technical work to inform and support the regulations. Much of that is done via MIIT’s subordinate orgs, such as CAICT and industry standards bodies, which set standards and carry out various testing, evaluation and certification functions.
Other relevant orgs include: the Ministry of Public Security (MPS) , which focuses on the law enforcement side of regulation; the Ministry of Foreign Affairs (MFA) , leads global AI diplomacy; the Ministry of Commerce , which deals with export/controls; and the **Ministry of…
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