Amanda Ge

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On 3 February 2026, the Ministry of Industry and Information Technology (MIIT), the sectoral regulator of the automotive sector, and the Cyberspace Administration of China (CAC), the designated data regulator, together with six other government authorities, published the Guidance for the Secure Cross-Border Transfer of Automotive Data (2026 Edition). This new guidance focuses on the…

Continue Reading China: New guidance on data transfer and identification of important data in the automotive sector

All data controllers processing personal data under the age of 14 (“minors“) must now submit an annual report to Chinese data regulator, the Cyberspace Administration of China (“CAC“). For 2025, the report must be submitted by 31 January 2026. There is no volume threshold, meaning that any data controller processing any…

Continue Reading CHINA: new mandatory reports to regulator on children’s data , initial deadline 31 January 2026

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