On November 30, 2022, OpenAI launched ChatGPT conversational artificial intelligence; with the latest version update, ChatGPT has demonstrated an impressive ability to understand natural language, making it an attractive tool for companies and individuals looking to provide customer service and support. GPT-3 uses textual data, mostly from publicly available information on the Internet, as training data. GPT-4, on the other hand, uses a large number of images in addition to textual data for training, and thus can process both textual and graphical data. The emergence of generative AI has greatly impacted human life, but it can be said that intelligent technology is a double-edged sword:rapid development of generative artificial intelligence (AI) technologies, on the one hand, it can improve efficiency and productivity, reduce costs and open new opportunities for economic growth, but on the other hand, the use of generative AI services to create synthetic content in the form of text, audio, video and images poses possible risks. To date, different regions around the world are at different stages of development of normative acts concerning generative AI.Using the comparative legal method and the method of system analysis, this article analyzes in detail the main models of legal regulation of generative AI in the modern world on the example of the UK, the USA, the European Union and China, noting the different approach in the development and adoption of relevant normative legal acts in the field of regulation of generative AI services.It especially reveals the Chinese government’s position on “development and security” and “innovation and governance” at present. The main trends of improving the regulation of generative AI services by China are proposed, and it is concluded that it is necessary to balance “rule of law” and “innovation” and promote the healthy development of generative AI.