China’s ACPAA Bans AI-Generated Patent Filings, Limits Fee Compet


On September 22, 2025, the Association of entirely Chinese patents lawyers (ACPAA) published the revised code of professional ethics and practice discipline for patent agents (专利代理职业道德与执业纪律规范) “To further improve the professional quality of patent agents, normalize the practice of patent agents and ensure the high quality development of the patent agencies” in China. Two key modifications include prohibitions to bring artificial intelligence to directly generate patent application documents and malfunction with the price of patent agency services. Earlier this year, Nanjing prohibited the use of AI in drafting patent application documents for pre-examination.

ACPAA is a voluntary pseudo-governmental organization for lawyers for Chinese patents which has been approved by the Ministry of Civil Affairs and National intellectual property administration of China (Cnipa). However, ACPAA application powers are limited to expulsion members. One of main objectives ACPAA consists in “strengthening the self -discipline of the profession, strengthening professional driving rules, improving the service of patent representation and other related practices and promoting the high quality development of the profession of patent representation”.

A translation of the two relevant articles follows:

Article 15 Patent agents must guarantee the quality of the services of patent agencies and will be responsible for the activity of patent agencies they sign.

Patent agents cannot use artificial intelligence to directly generate patent application documents for final submission.

Article 48 Patent agencies should not participate in unfair competition as follows:

(1) Make false complaints on your own professional capacities, maliciously express comparative advertising with other patent agencies;

(2) Malvisory lowering the price of patent agencies;

(3) express or involve a special relationship with a legal body, an administrative body, a social group or their staff;

(4) Proactively contact customers of other patent agencies concerning specific cases or undertake patent agency activities obtained by the means mentioned above;

(5) Solicit business by making negative comments on other patent agencies;

(6) Make inappropriate promises concerning patent applications or results of patent cases;

(7) Solicit business by offering or promising to offer illegal commissions, bribes, reference costs or other advantages;

(8) counterfeit on the commercial secrets of other patent agencies;

(9) Other acts that undermine the order of fair competition in industry.

The full text of the revised code can be found here (Chinese only).

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