On 28 October 2025, China passed amendments to the Cybersecurity Law, marking the first update since its enactment in 2016. These amendments reflect China’s heightened focus on cybersecurity and AI governance and are scheduled to take effect on 1 January 2026.
Key Updates
The amendments primarily focus on the law’s enforcement provisions. Key updates include:
Continue Reading CHINA: Amendments to Cybersecurity Law Effective 1 January 2026
The Cyberspace Administration of China (“CAC“) has recently published the Administrative Measures for Network Security Incident Reporting (“Measures“), which provide further guidance on when and how to report network security incidents under existing laws such as the Cybersecurity Law, the Data Security Law and the Personal Information Protection Law. The Measures
Continue Reading CHINA: new stricter and 4-hour data breach reporting requirements for certain incidents
It’s well-known that China’s data protection laws define sensitive personal information very differently to other jurisdictions. Instead of a closed list of data types, sensitive personal information in China has traditionally been defined by reference to a broad “risk of harm” test. A new national standard, which will come into force on 1 November 2025
Continue Reading CHINA: definition and handling of Sensitive Personal Information helpfully clarified
While appointing and registering a DPO has been mandatory in China for many years, a portal has now finally been established for organisations to register those DPOs with the China data protection authority. This resolves long-standing uncertainty over how DPOs must be registered, and over relevant qualifications and location of the DPO. The deadline for
Continue Reading CHINA: DPOs must be registered before 29 August 2025
The Cyberspace Administration of China (CAC) released an important Q&A on cross-border data transfer requirements and policies in early April, providing clarification on a number of issues of concern to companies in China. Key points include:
Data other than important data and personal data can flow freely across borders. The Q&A emphasizes that, in principle
Continue Reading China: CAC publishes official Q&As for cross-border data transfer regulation
Recently, the Cyberspace Administration of China (CAC), which is the primary data regulator in China, published a newsletter about the government authorities’ enforcement of Apps and websites that violated personal data protection and cybersecurity laws during the year 2024.
Based on the official statistics, during 2024, the CAC interviewed 11,159 website platforms, imposed warnings or
Continue Reading CHINA: Recent Enforcement Trends
Chinese data regulators are intensifying their focus on the data protection compliance audit obligations under the Personal Information Protection Law (“PIPL“), with the release of the Administrative Measures for Personal Information Protection Compliance Audits (“Measures“), effective 1 May 2025.
The Measures outline the requirements and procedures for both self-initiated and regulator-requested
Continue Reading CHINA: Mandatory Data Protection Compliance Audits from 1 May 2025
On 3 January 2025, the Cyberspace Administration of China (“CAC“) released for public consultation the draft Measures for Certification of Personal Information Protection for Cross-Border Transfer of Personal Information (“Draft Measures“). This regulation represents the final piece in the CAC’s regulatory framework for the three routes to legitimize cross-border transfers of personal data
Continue Reading CHINA: Draft Regulation on Certification for Cross-Border Data Transfers Published
Additional and clarified data compliance obligations will soon come into force under the long-awaited Network Data Security Management Regulation (“Regulation“), which was released on 30 September 2024. The Regulation is formulated under the existing data protection framework pillars of the Cyber Security Law, the Data Security Law and the Personal Information Protection Law
Continue Reading CHINA: Enhanced and clarified data compliance obligations on handlers of “network data”, covering personal information and important data, and operators of online platforms from 1 January 2025
We previously wrote about proposed changes to the definition of sensitive personal information under a June 2024 draft of the Guide for Sensitive Personal Information Identification (“Guide“). The Guide has now (September 2024) been finalized and issued by the National Information Security Standardization Technical Committee (TC260). Helpfully, it gives organisations greater scope to
Continue Reading China: New definition and guidelines on Sensitive Personal Information now finalised
