Executive Summary & TL;DR

This report provides a comprehensive strategic analysis of mainland China’s Brain-Computer Interface (BCI) industry, covering its current development status, technology commercialization, and clinical applications. The core findings can be summarized as follows:

China’s BCI industry is in a phase of government-led, hyper-speed development, driven by explicit top-level national design and fierce regional competition between the two tech hubs of Beijing and Shanghai. In the non-invasive BCI sector, China has already established itself as a global leader, thanks to its deep technological accumulation and broad application exploration. Concurrently, in the more technologically challenging invasive sector, China is catching up at a remarkable pace. Recent landmark clinical breakthroughs in motor function restoration and language decoding have significantly narrowed the gap with Western pioneers like Neuralink.

The entire industry ecosystem is maturing from pure academic research towards viable commercialization. A cohort of well-funded startups is emerging, while the initial establishment of regulatory approval and insurance reimbursement pathways is paving the critical “last mile” for industrialization. However, the path forward is not without significant challenges, including core technology bottlenecks (such as the long-term biocompatibility of electrodes and the design and manufacturing of high-performance chips), a severe shortage of interdisciplinary high-end talent, and the urgent need to build robust ethical and data governance frameworks.

Overall, the trajectory of China’s BCI industry is clearly set. Its goal is not merely to achieve technological parity with the world’s most advanced levels but to compete for global leadership in this future-defining industry by 2030 through a comprehensive strategic layout.

TL;DR:

China’s BCI industry is advancing at full speed, propelled by strong national policies, with regional competition between Beijing and Shanghai acting as dual engines of growth. China leads globally in non-invasive technology, while recent major clinical breakthroughs in invasive technology (for motor and language function restoration) are rapidly closing the gap with the West. The ecosystem is shifting from research to commercialization, evidenced by well-funded startups and established regulatory and insurance payment pathways. However, key challenges remain, including core technology bottlenecks, a shortage of interdisciplinary talent, and the absence of a comprehensive ethical and data security framework. China’s objective is clear: to become the global leader in the BCI field by 2030.

I. The Policy Superstructure: Forging a National BCI Champion

China’s BCI strategy exhibits a classic top-down, state-driven characteristic. This top-level design establishes the foundational policy and regulatory environment for all subsequent industry developments.

1.1 National Ambition: BCI as a Core “Future Industry”

The Chinese government has elevated BCI to the core level of its national strategy. The joint action of seven key ministries, including the Ministry of Industry and Information Technology (MIIT), the National Development and Reform Commission (NDRC), and the National Medical Products Administration (NMPA), clearly indicates this.¹ In July 2025, these seven departments jointly issued the “Implementation Opinions on Promoting the Innovative Development of the BCI Industry,” setting clear and ambitious goals for the industry’s development.³

The policy document’s objectives are planned in two phases:

• By 2027: Achieve breakthroughs in key technologies (such as electrodes and chips), initially establish an advanced technology and industrial system, and promote the application of BCI products in key areas like healthcare and industrial manufacturing.³

• By 2030: Significantly enhance the industry’s innovation capabilities, form a secure and reliable industrial system, cultivate 2 to 3 globally influential leading enterprises, and achieve a comprehensive strength that ranks among the world’s foremost.³

This policy is not an isolated measure but part of China’s grand blueprint to promote “New Quality Productive Forces” and achieve self-reliance in critical future technologies.³ The joint participation of seven major ministries sends a powerful signal: this is a systemic project requiring the mobilization of whole-of-government resources. This cross-departmental coordination mechanism is far more significant than simple research funding. The MIIT’s involvement points to industrialization and advanced manufacturing, the NDRC’s participation relates to long-term economic planning and resource allocation, the Ministry of Education focuses on talent pipeline development, and the NMPA’s inclusion signals a potentially accelerated regulatory approval pathway tailored for innovative products. This structure indicates that the government views BCI development as a complex ecosystem challenge, not a linear R&D problem, aiming to systematically clear potential obstacles along the entire value chain from lab to market by simultaneously advancing manufacturing, investment, regulation, and human capital.

1.2 The Dual-Engine Model: “Competitive Federalism” between Beijing and Shanghai

In January 2025, Beijing and Shanghai almost simultaneously released their respective action plans for BCI industry development, marking the official start of a fierce regional race to become China’s BCI industry hub.⁵

• Beijing Action Plan (2025-2030): Leveraging Beijing’s strengths in basic research and top universities, this plan aims to establish the city as a global “source of technological innovation.” Its strategic focus is on breaking through underlying core technologies, with a plan to cultivate 3-5 globally influential tech leaders by 2030.⁵

• Shanghai Action Plan (2025-2030): Shanghai’s plan is more focused on building a complete industrial chain, covering the entire process from R&D and clinical translation to large-scale production. The plan proposes to achieve “high-quality brain control” and the comprehensive clinical application of products by 2030, fully leveraging its industrial cluster advantages in biomedicine, artificial intelligence, and integrated circuits.⁵ Shanghai’s plan specifies key infrastructure projects, such as building Good Manufacturing Practice (GMP)-compliant micro-nano fabrication platforms and Good Laboratory Practice (GLP)-compliant animal experiment platforms.⁹

This parallel regional competition is not simple resource duplication but a form of “A/B testing” tacitly approved or even encouraged at the national level. Beijing’s model represents a path centered on deep R&D and source innovation, while Shanghai’s model represents a path centered on industrial ecosystem integration and rapid commercialization. This “competitive federalism” allows the central government to draw lessons from two different development models to optimize and refine the overall national strategy. By stimulating healthy competition between the two metropolises, the pace and efficiency of development far exceed what a single, rigid national plan could achieve, thereby building a more resilient and dynamic national innovation system.

1.3 Paving the Commercialization Path: Regulation, Standards, and Insurance Reimbursement

China is actively building the “soft infrastructure” to support BCI commercialization, ensuring that technological breakthroughs can be smoothly translated into market products.

• Accelerated Regulatory Approval: The National Medical Products Administration (NMPA) has explicitly stated that it will provide “priority support” and “strengthened registration guidance” for key medical device products like implantable BCIs.³ For example, BoRuiKang’s product has successfully entered the national “special review procedure for innovative medical devices,” which is expected to significantly shorten its time to market approval.¹⁰

• Standardization Efforts: The NMPA is accelerating the formulation of relevant technical standards. For instance, an industry standard plan for “Quality Requirements and Evaluation Methods for EEG Datasets Used in Artificial Intelligence Algorithms for Medical Devices with BCI Technology” is already underway.⁵ The government has also initiated the establishment of a BCI Standardization Technical Committee to lay the groundwork for the industry’s standardized development.¹¹

• Insurance Reimbursement Breakthrough: The most decisive step among all commercialization initiatives is the National Healthcare Security Administration’s establishment of separate billing codes for BCI technology. The “Guidelines for Establishing Medical Service Price Items for the Nervous System,” released in March 2025, explicitly added price items such as “non-invasive BCI adaptation fee” and “invasive BCI implantation fee, removal fee”.⁸ Currently, several provinces, including Hubei, Zhejiang, and Guangdong, have already implemented specific billing standards.²

The establishment of independent insurance reimbursement codes is the most significant non-technical milestone in the development of China’s BCI industry. This move fundamentally solves the core business question of “who pays,” greatly reducing market entry risks. For investors and companies, it provides a clear signal that BCI technology has a viable, scalable business model in China, and its future market will no longer be limited to self-paying high-net-worth individuals or research project funds. By establishing a reimbursement pathway before products are widely available, the government demonstrates its long-term commitment to the industry and creates a predictable revenue environment. This not only incentivizes companies to invest heavily in expensive clinical trials but also attracts institutional investors with “patient capital,” such as China Life Insurance, who understand and are willing to support the long road to profitability.⁴ This move successfully transforms BCI from a high-risk technological venture into a strategic investment with manageable risks and foreseeable returns.

Table 1: Comparative Analysis of National and Local BCI Strategies

Policy Area	National “Implementation Opinions”	Beijing “Action Plan”	Shanghai “Action Plan”
Overall Goal	Achieve world-class comprehensive strength by 2030, forming a secure and reliable industrial system.	Build a globally influential hub for technological innovation, application leadership, and industrial clustering.	Create a global innovation highland for BCI products, with core links of the industrial chain being self-controllable.
Key Metrics	Cultivate 2-3 globally influential leading enterprises.	Cultivate 3-5 globally influential leading enterprises and 100 innovative SMEs.	Attract and cultivate 5+ core technology enterprises and 10+ industrial chain backbone enterprises.
Strategic Focus	Enhance industrial innovation capabilities, with equal emphasis on technological breakthroughs and application scenario development.	Focus on frontier basic research and key core technology breakthroughs, strengthening original innovation capabilities.	Emphasize the cultivation of the entire industrial chain, accelerating productization, clinical application, and ecosystem building.
Key Initiatives	Deploy major projects, strengthen basic hardware and software R&D, and promote applications.	Establish key laboratories, build common technology service platforms, and expand diverse application scenarios.	Build three major platforms for micro-nano fabrication, animal experiments, and data services; support major product R&D.
Financial Support	Promote investment from national-level funds, implement the “Technology-Industry-Finance Integration” special project.	Strengthen diversified financial support, guiding social capital participation.	Establish special funds, support products entering the special review procedure for innovative medical devices.

II. The R&D New Ecosystem: Technological Pathways and Innovation Hubs

This chapter aims to map out the technological landscape of China’s BCI, detailing its parallel development of multiple technological pathways and analyzing the core academic institutions driving basic research.

2.1 A Three-Pronged Approach: Invasive, Semi-Invasive, and Non-Invasive

China has adopted a strategy of parallel development across multiple technological pathways, recognizing that different application scenarios require varying degrees of invasiveness, thereby seeking the optimal balance between risk and performance.⁸

• Non-Invasive: This is the area where China’s technology is most mature and the industrialization process is fastest. Research forces, represented by Professor Gao Xiaorong’s team at Tsinghua University, have achieved world-leading results in non-invasive systems based on Steady-State Visually Evoked Potential (SSVEP), with thought-based typing speeds comparable to invasive methods.¹⁵ In terms of commercial applications, companies like BrainCo have successfully applied non-invasive technology to rehabilitation aids and consumer health products.¹⁶ The advantages of this route are high safety, low cost, and ease of promotion, but its core challenge lies in the signal quality being susceptible to interference, with limited signal-to-noise ratio and spatial resolution.¹³

• Invasive: This technology involves surgically implanting microelectrode arrays directly into the cerebral cortex to obtain the highest fidelity neural signals.¹³ Although China’s development in this area historically lagged behind the United States, it has been catching up at an astonishing speed in recent years. Emerging companies like Stairway Therapeutics and Neuro-X are conducting landmark clinical trials that directly benchmark against the international cutting edge.⁵ The main obstacles for invasive technology are the inherent risks of surgery, the long-term biocompatibility of implanted electrodes, and the stability of signal recording.¹⁵

• Semi-Invasive: This is an innovative path aimed at balancing risk and performance, reflecting the pragmatism and ingenuity of the Chinese research community. A typical representative is the NEO system, developed through a collaboration between Professor Hong Bo’s team at Tsinghua University and the company BoRuiKang. This system places flexible electrode sheets under the skull but above the dura mater, meaning it does not directly penetrate the brain’s neural tissue.¹⁰ This “close but not touching” design significantly reduces the risks of surgical trauma and immune rejection while capturing neural signals that are far clearer and more stable than scalp electroencephalography (EEG).

The development of the semi-invasive route is not just a technical compromise but a highly forward-thinking market strategy. It deeply understands the medical market’s logic of balancing risk and reward. While the world’s attention is focused on the “moonshot” of high-density cortical implants (like Neuralink), a semi-invasive system that is “good enough” in performance and significantly lower in risk may gain regulatory approval and widespread market acceptance much faster. For areas with urgent clinical needs such as paralysis and epilepsy, this solution offers a highly attractive risk-benefit ratio. This allows Chinese companies to potentially capture a lucrative medical market in the short term, accumulating valuable clinical data and commercial operational experience, thereby establishing a solid market position and technological moat before more disruptive invasive technologies fully mature.

2.2 Academic Vanguards: Universities as Innovation Engines

China’s top-tier BCI innovations are highly concentrated in a few elite academic institutions, which form the technological wellspring of the entire industry.

• Tsinghua University: The undisputed national leader, with multiple top teams making contributions across different technological pathways. Professor Hong Bo’s team is the core R&D force behind the semi-invasive NEO system ²¹, while Professor Gao Xiaorong’s team maintains an international lead in the field of encoding and decoding algorithms for non-invasive BCIs.¹⁵

• Fudan University and its affiliated Huashan Hospital: As a core hub for clinical translation, Huashan Hospital’s formidable neurosurgery capabilities make it the preferred partner for innovative companies. They are collaborating with Neuro-X on language decoding clinical trials ⁵ and with Stairway Therapeutics on prospective studies for motor function restoration.¹⁸

• Tianjin University: Relying on its Haihe Laboratory of Brain-Machine Interaction and Human-Machine Integration, Tianjin University has built a vast patent portfolio in the non-invasive BCI field and has made significant breakthroughs in cutting-edge applications like mind-controlled drones.⁸

• Beijing Institute for Brain Disorders: This is a government-supported, industrialization-oriented new type of R&D institution. The institute and its subsidiary, Core-Intelli, are actively advancing the R&D and clinical validation of the “Bei Nao No. 1” (semi-invasive) and “Bei Nao No. 2” (invasive) intelligent BCI systems.²³

A deeper analysis of these success stories reveals that the development of high-end BCI in China generally follows an efficient “Golden Triangle” collaboration model. This model consists of three key players: a top university providing core intellectual property and talent (e.g., Tsinghua University); a top-tier hospital offering world-class clinical experience, surgical skills, and valuable patient resources (e.g., Huashan Hospital, Xuanwu Hospital); and a venture capital-backed startup responsible for translating research outcomes into standardized products and driving their commercialization (e.g., BoRuiKang, Stairway Therapeutics). This tight synergy among industry, academia, research, and medicine is the core mechanism for China to accelerate the transition of technological achievements from the lab to the clinic, crossing the “valley of death.” It ensures that basic research is closely aligned with clinical needs from the outset, startups can easily access top medical resources for trials, and hospitals can be the first to engage with cutting-edge treatment technologies. For evaluating the potential of a Chinese BCI startup, examining the strength of its “Golden Triangle” partners is often the most effective predictor of its success.

III. The Commercialization Frontier: Core Innovators and Market Dynamics

This chapter will focus on the leading companies translating cutting-edge research into tangible products and analyze the broader market environment, including investment trends and the supply chain landscape.

3.1 Innovator Profiles: Invasive and Semi-Invasive Leaders

• Stairway Therapeutics: This company focuses on developing a minimally invasive implantable BCI system, with its core technology being ultra-flexible neural electrodes. Its implant is reportedly only half the size of Neuralink’s product.¹⁸ Stairway Therapeutics is the first company in China and the second globally to enter the clinical trial stage for a high-channel invasive BCI product, with an initial target for product launch in 2028.¹⁸

• Neuro-X: As a key partner of Fudan University and Huashan Hospital, Neuro-X is known for its proprietary invasive flexible electrode technology. Its landmark achievement was successfully decoding a patient’s imagined Mandarin phrase “Happy New Year 2025” in a clinical trial.⁵ Furthermore, the company has achieved a decoding speed of up to 49.6 Chinese characters per minute, a significant technological feat in the field of language BCI, especially considering the complexity of the Chinese writing system.²⁵

• BoRuiKang: As the commercialization partner for the semi-invasive NEO system from Professor Hong Bo’s team at Tsinghua University, BoRuiKang’s product is the first BCI product in China to enter the national special review procedure for innovative medical devices, paving the way for its subsequent commercialization.¹⁰ The company is planning to launch a large-scale clinical trial involving 30 to 50 subjects across multiple centers nationwide.¹⁰

3.2 Innovator Profiles: Non-Invasive Technology Pioneers

• BrainCo: Founded by Han Bicheng, a graduate of Harvard University, and industrialized in Hangzhou ²⁶, BrainCo has become one of the leading companies in the global non-invasive BCI field, with cumulative financing exceeding $200 million.²⁷ The company focuses on real-world applications of its technology. Its most notable products are the intelligent bionic hand and leg, which have received marketing approval from the U.S. Food and Drug Administration (FDA).¹⁶ Additionally, the company is actively exploring the application of its technology in areas such as autism intervention, education, and sleep health.¹⁶

3.3 Investment, Market Trajectory, and Supply Chain Analysis

The Chinese BCI market is experiencing rapid growth. According to data from CCID Consulting, the market size is expected to exceed 5.5 billion RMB by 2027.²⁴ The capital market’s enthusiasm for this sector remains high, with diversified funding sources including “national team” funds like the National Manufacturing Transformation and Upgrading Fund, as well as active private capital.² Notably, state-owned financial giants like China Life Insurance have also made deep strategic investments, viewing it as a long-term strategic asset and leveraging their “patient capital” advantage to support the technology’s long-term development.⁴

However, the industry’s rapid development has also exposed weaknesses in its supply chain. Currently, China still relies to some extent on foreign suppliers for core components such as high-performance electrode materials and low-power specialized chips, which poses a potential strategic risk.¹⁰ Shanghai’s action plan explicitly states that it will prioritize support for the R&D of micro, highly biocompatible, high-throughput flexible electrodes and key materials, aiming to build a self-reliant upstream supply chain.⁹

This financing structure, with deep involvement from state-backed “patient capital,” creates a competitive landscape distinctly different from the West. The Western BCI field is predominantly led by tech billionaires (like Musk) and venture capital (VC), whose investment logic is more geared towards seeking rapid, high-multiple returns. In contrast, China’s model provides a more stable and long-term funding environment, less susceptible to short-term market sentiment fluctuations. This allows companies like Stairway Therapeutics to more confidently plan R&D roadmaps spanning several years (e.g., its 2028 launch target). In the long run, this financial stability may give them greater resilience and endurance in competition with VC-backed companies that rely on continuous fundraising and are more vulnerable to market volatility. The national-level push for localizing the core supply chain is intended to provide a solid safeguard for this long-term strategy, insulating it from geopolitical risks.

Table 2: Overview of Major Chinese BCI Companies

Company Name	Technology Route	Core Product/Application	Clinical Stage/Status	Key Partners	Funding (Est.)	Key Milestones
Stairway Therapeutics	Invasive	High-channel minimally invasive system for motor function restoration	First-in-Man (FIM) Clinical Trial	Fudan University Affiliated Huashan Hospital	Series A over 300M RMB	First high-channel invasive BCI company in China to enter FIM stage
Neuro-X	Invasive	Flexible electrode system for language and motor decoding	Clinical Trial	Fudan University Affiliated Huashan Hospital, TCCI	Series A and beyond	World’s first successful clinical trial for Chinese language decoding
BoRuiKang	Semi-invasive	NEO wireless minimally invasive system for motor function restoration	Preparing for multi-center registration clinical trial	Tsinghua University, Xuanwu Hospital, Tiantan Hospital	Undisclosed	Product entered national special review procedure for innovative medical devices
BrainCo	Non-invasive	Intelligent bionic hand/leg, autism intervention devices	Product Marketed (FDA Approved)	Harvard University, MIT	Over $200M cumulative	First BCI unicorn company in China
Core-Intelli	Invasive/Semi-invasive	“Bei Nao No. 1”, “Bei Nao No. 2” intelligent BCI systems	Clinical Validation Stage	Beijing Institute for Brain Disorders	Government-backed	Completed 5 patient implants of “Bei Nao No. 1”

IV. From Lab to Clinic: Landmark Trials and the Path to Application

This chapter shifts from technological potential to clinical reality, showcasing China’s significant progress in BCI clinical translation through detailed case studies.

4.1 Case Study: Restoring Motion

• Tsinghua/BoRuiKang NEO System Clinical Trial: This is a high-profile clinical trial. A patient who had been a high-level quadriplegic for 14 years due to a car accident, after being implanted with the semi-invasive NEO system, successfully controlled a pneumatic glove with his “thoughts” to independently grasp a water bottle and drink from it.²¹ This trial, conducted at Beijing’s Xuanwu Hospital and Tiantan Hospital, powerfully validated the feasibility and effectiveness of the “epidural” electrode approach. The system uses wireless power and data transmission, and the internal device requires no battery, theoretically allowing for lifelong use.²¹

• Stairway Therapeutics Clinical Trial: This is China’s first “First-in-Man” (FIM) trial for a high-channel cortical implantable BCI system. Just over a month after surgery at Shanghai’s Huashan Hospital, a quadriplegic patient was able to precisely control a computer cursor with his thoughts and play a racing game.¹⁸ The significance of this trial is that it marks China’s capability to directly compete with the top international level in the most cutting-edge field of invasive BCI.

4.2 Case Study: Decoding Language

• Neuro-X Clinical Trial: In this trial, conducted in collaboration with Huashan Hospital, a brain tumor patient, using Neuro-X’s invasive flexible electrode system, successfully had the phrase “Happy New Year 2025,” which he conceived in his mind, decoded.⁵ The decoded command was then sent to a robotic arm, which made a heart-shaped gesture. This achievement opens up a new path for restoring communication abilities for patients with aphasia, amyotrophic lateral sclerosis (ALS), and other conditions that cause loss of language function. The reported decoding speed of 49.6 Chinese characters per minute is highly competitive globally, and this achievement is even more remarkable given the complexity of the Chinese language.²⁵

These high-profile clinical successes hold value far beyond science and medicine. They are also powerful public relations and policy advocacy tools. The image of a man paralyzed for 14 years drinking on his own again ²¹, or a patient conveying New Year’s greetings through thought ⁵, constructs a highly compelling and positive narrative. This narrative can effectively garner public support, legitimize continued massive government investment, and attract top talent to the field. It successfully transforms an abstract, esoteric technological concept into a concrete, tangible, and hopeful human story, thereby injecting powerful momentum into the accelerated development of the entire industry ecosystem. This creates a virtuous cycle: successful clinical trials generate positive media coverage, which in turn enhances public and policymaker support, ultimately translating into more funding and a more favorable policy environment, creating the conditions for larger and more ambitious clinical research. This strategic narrative management around key achievements has become an indispensable part of China’s strategy to accelerate the development of its BCI industry.

Table 3: Summary of Major Publicly Disclosed BCI Clinical Trials in China

Lead Institution/Hospital	Corporate Partner	Technology (Device Name, Type)	Primary Goal	Patient Condition	Key Reported Outcome	Status/Next Steps
Tsinghua Univ./Xuanwu Hospital	BoRuiKang	NEO System, Semi-invasive	Motor function restoration	High-level quadriplegic for 14 years	Achieved mind-controlled robotic glove for self-drinking	Second case completed at Tiantan Hospital, preparing for multi-center trial
Fudan Univ./Huashan Hospital	Stairway Therapeutics	High-channel cortical implant system, Invasive	Motor function restoration	Quadriplegic	1-month post-op, achieved mind control of cursor, gaming	Plan for 3-4 FIM cases, start large-scale registration trial early next year
Fudan Univ./Huashan Hospital	Neuro-X	Flexible electrode system, Invasive	Language decoding	Brain injury/tumor	Successfully decoded “Happy New Year 2025”, controlled robotic arm	Ongoing clinical research to improve decoding accuracy and speed
Beijing Inst. for Brain Disorders	Core-Intelli	Bei Nao No. 1, Semi-invasive	Motor function restoration	Undisclosed	System is stable, capable of collecting high-quality signals	5 implants completed, in clinical validation phase

V. Overcoming Headwinds: Challenges, Risks, and Ethical Considerations

To provide a balanced perspective, this chapter will examine the significant challenges and potential risks that could impede the development of China’s BCI industry.

5.1 Technology Gaps and Supply Chain Vulnerability

Despite rapid progress, China still faces key bottlenecks at the core technology level of BCI. For invasive devices, the long-term biocompatibility of materials and the stability of signal recording remain critical challenges to overcome.¹⁵ For non-invasive devices, further improving the signal-to-noise ratio and the accuracy of decoding algorithms is key to their broader application.¹¹ Furthermore, the industry’s reliance on foreign supply chains for some core components (such as high-performance chips and special biomaterials) constitutes a significant strategic vulnerability.²⁹ For this reason, Shanghai’s action plan explicitly prioritizes tackling key technologies like high-throughput flexible electrodes and low-power chips, and cultivating a domestic supply chain.⁹

5.2 The Interdisciplinary Talent War

BCI is a deeply interdisciplinary field, and its development requires a large number of composite talents who are proficient in multiple fields simultaneously, including neuroscience, materials science, microelectronics, artificial intelligence, and clinical medicine. Multiple reports clearly indicate that China currently faces a shortage of high-end talent reserves, and the existing education and training systems need to be optimized to better meet the industry’s demand for interdisciplinary talent.¹¹ To this end, the national top-level design plan also specifically emphasizes strengthening the cultivation of professional talent in related disciplines and actively attracting top overseas talent.³

5.3 The Governance Imperative: Ethics, Data Security, and “Brain Privacy”

As the technology develops further, the profound ethical issues behind it are becoming increasingly prominent. China’s Ministry of Science and Technology has issued the “Ethical Guidelines for Brain-Computer Interface Research,” which preliminarily defines ethical boundaries, emphasizing that research should primarily focus on restorative rather than enhancement applications.¹¹ Major societal concerns are centered on data security (how to prevent “brain hacking”), the privacy of neural data, and the legal definition of the ownership of “thought data”.¹¹ It is currently widely believed that the development of relevant laws, regulations, and supervisory frameworks has lagged behind the pace of technological development, especially regarding the ownership and use boundaries of EEG data, where legal ambiguities still exist.¹¹

At the level of ethical governance, China’s chosen path may diverge significantly from the Western world. The emphasis in official documents on “social value” and “public health needs” ³⁰ suggests an ethical framework that is more focused on collective interests and state-defined therapeutic goals. This contrasts with the Western bioethics discourse, which is centered on individual autonomy and cognitive liberty. This fundamental difference in ethical philosophy will become increasingly important as technology evolves from “restoration” to “enhancement.” A cognitive enhancement technology accepted in one jurisdiction may be strictly limited to therapeutic use in another. This will not only affect product design and market access but could also create friction in international cooperation, global standard-setting, and cross-border data flows, potentially leading to a “techno-ethical divide” in the global BCI market based on different ethical rules.

VI. Strategic Outlook and Recommendations

This chapter will synthesize all the preceding analysis to provide a forward-looking forecast for the industry’s future trajectory and offer actionable strategic recommendations for stakeholders in various fields.

6.1 Future Trajectory (2025-2030): Key Milestones to Watch

Based on clear policy objectives and the current strong development momentum, several key development nodes can be anticipated for China’s BCI industry in the next five years:

• First Product Approval: The National Medical Products Administration (NMPA) approves the first domestically produced invasive or semi-invasive BCI medical device for the market. Based on current clinical progress, BoRuiKang’s NEO system or Stairway Therapeutics’ product is most likely to be the first to cross the finish line.

• Expansion of Clinical Applications: The indications for clinical trials will expand from the current focus on spinal cord injury to more complex neurological diseases, such as stroke sequelae, epilepsy, and Parkinson’s disease.

• Emergence of a Commercial Unicorn: The first Chinese BCI “unicorn” company with significant annual revenue will emerge, marking the industry’s transition from relying on financing to self-sustainability.

• Breakthrough in Non-Medical Applications: BCI technology will begin to see initial commercial applications in non-medical fields (such as high-end manufacturing, education, and entertainment), although the scale may be limited.

6.2 Competitive Landscape: China vs. The World

An objective assessment of China’s position in the global BCI field leads to the following conclusions: In the application of non-invasive BCI, China is already a world leader, thanks to its vast market, active innovative companies, and rapid product iteration. In the more technologically demanding invasive field, although there is still a gap compared to pioneers like the United States in terms of the number of implanted patients and long-term chronic data accumulation, China’s development speed is remarkable. Its unique “Golden Triangle” model of industry-academia-research-medicine collaboration, ample national-level funding support, and increasingly clear regulatory pathways together form a powerful engine for catching up. It is foreseeable that by 2030, China is not only expected to achieve overall parity with the world’s advanced levels but may also achieve global leadership in sub-fields such as semi-invasive technology and specific language decoding.

6.3 Strategic Recommendations

• For Investors:

  • Prioritize companies that have formed a solid “Golden Triangle” (top university-top hospital-startup) partnership, as this is the core guarantee of their technology transfer capabilities and clinical resource advantages.

  • Focus on companies whose product pipelines have entered or have a clear plan to enter the NMPA’s special review procedure for innovative medical devices, as this indicates a higher certainty of their commercialization path.

  • Pay close attention to the upstream supply chain, especially in the areas of high-performance electrodes, specialized chips, and biocompatible materials. As the state promotes supply chain self-reliance, this area will become a focus of government investment and holds huge growth potential.

• For Corporate Strategists (Global BCI Companies):

  • The positioning of the Chinese market must be re-evaluated. China is no longer just a sales market to be developed but a rising power with strong competitors and a significant source of innovation.

  • Establishing partnerships with top academic labs or clinical centers in China could be an effective way to enter this complex market and access cutting-edge innovation.

  • The development of Chinese technical standards and ethical norms must be closely monitored, as they may differ from mainstream international standards, which will have a profound impact on future product access and market strategy.

• For Policymakers (Non-Chinese Regions):

  • The systematic, state-driven industrial policy adopted by China in the BCI field provides a case study worth examining. Its practice of proactively establishing insurance reimbursement codes and streamlining regulatory approval processes in the early stages of commercialization offers important lessons for accelerating the development of their own domestic industries.

  • To maintain global competitiveness, it is crucial to formulate a comprehensive and coherent national-level BCI development strategy.

  • Priority should be given to promoting international dialogue and coordination on BCI ethical norms and data-sharing protocols. This is essential to prevent global governance fragmentation and to build an open, secure, and responsible global BCI innovation ecosystem.

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8. 突破与挑战：脑机接口产业化有多远, https://gdstc.gd.gov.cn/kjzx_n/mtjj/content/post_4710929.html

9. 关于印发《上海市脑机接口未来产业培育行动方案（2025-2030年）》的通知, https://stcsm.sh.gov.cn/zwgk/ghjh/20250110/020cb0c1341f4d1680f264f5c6502a91.html

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16. 脑机领域最强大脑加入BrainCo强脑科技两亿美元打造最强非侵入式脑机接口底层技术, https://stcsm.sh.gov.cn/xwzx/kjzl/20211222/5f5c2d02d108432e949a3cbb9fb4ffe7.html

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20. 脑机接口人体试验：谁的未来更光明 - 清华大学, https://www.tsinghua.edu.cn/info/1182/110136.htm

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25. 让癫痫患者用意念玩《黑神话：悟空》！这家中央科创区企业获评上海新兴产业“八大赋能者”之一, https://www.shhuangpu.gov.cn/xw/001015/20250723/8626d82f-b1eb-4eaf-a72a-ac0648bc48a2.html

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27. 浙江省专业技术人才管理服务平台, https://zcps.rlsbt.zj.gov.cn/028/client/page6/table208.jsp?column1=8ad500538fde3baa018fec2e7122011b&t=1726272000037

28. Neuralink迎来中国首位挑战者：BrainCo完成2亿美金融资产品获美国FDA认证 - 财联社, https://m.cls.cn/detail/1180252

29. 2021年中国脑机接口平台行业概览, https://pdf.dfcfw.com/pdf/H3_AP202201121539917091_1.pdf?1641976029000.pdf

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31. 清华大学完成首例无线微创脑机接口临床试验，帮助四肢瘫痪者实现自主脑控喝水 - 生物谷, https://news.bioon.com/article/ffc981206947.html

32. 清华大学合作成功进行无线微创脑机接口临床试验, https://www.tsinghua.edu.cn/info/3045/110266.htm

33. 脑机接口技术伦理规范考量- PMC, https://pmc.ncbi.nlm.nih.gov/articles/PMC10162913/

34. 全球脑机接口战略政策比较及对我国的启示, http://www.xml-data.cn/KXYSH/html/1b047a93-a7ef-4114-b249-1c253a1e56c8.htm