Title：China’s Proactive Role in Shaping Global AI Governance: A WTO-Centric Analysis of Digital Sovereignty and Trade in Services

Author：Zihan Chen

Abstract：The advent of Generative Artificial Intelligence (GAI) has ignited a global imperative for regulatory frameworks, creating significant friction with the established principles of the multilateral trading system, particularly in the area of international trade in services. As a pivotal actor in both Artificial Intelligence (AI) development and regulation, the People’s Republic of China has meticulously constructed a sophisticated legal and administrative architecture to govern GAI services. This framework, deeply rooted in a vision of “digital sovereignty”, prioritizes national security, social stability, and technological self-reliance. This article offers a comprehensive analysis of China’s GAI governance model, critically assessing its compatibility with the core disciplines of the World Trade Organization (WTO). It deconstructs China’s key regulatory instruments, including the Cybersecurity Law, the Data Security Law, and the specific measures for GAI, and examines their interaction with foundational WTO agreements, primarily the General Agreement on Trade in Services (GATS). The analysis focuses on the friction points arising from China’s data governance regime and content moderation requirements, evaluating them against GATS principles of market access, national treatment, and domestic regulation. Furthermore, the article scrutinizes the viability of China invoking GATS general and security exceptions to justify its measures. It argues that China’s approach constitutes a cohesive, development-oriented alternative to the liberal, market-driven model of digital governance, representing a sovereignty-focused strategy rather than a set of isolated trade policies. The article concludes by assessing China’s strategic evolution from a rule-taker to a proactive rule-shaper in global AI governance, particularly through its engagement in the Joint Statement Initiative (JSI) on e-commerce and its pursuit of bilateral and multilateral pathways to lead the formulation of international services trade AI standards, while also considering the systemic implications for the future of the WTO in the digital era.

Keywords：GAI, China, WTO, GATS, Digital Sovereignty, JSI