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China (Mainland): compliance overview

20 regulations, 102 mapped obligations and 5 data-transfer routes, organised by when they start to bind you and what you have to do.

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Regulatory timeline: what comes next

  1. 2025-01-01

    Network Data Security Management Regulations add implementing detail

    Personal Information Protection Law

  2. 2025-01-01

    Network Data Security Management Regulations flesh out the important-data duties

    Data Security Law

  3. 2025-01-01

    Regulations enter into force

    Regulations on Network Data Security Management

  4. 2025-01-01

    Art. 19 of the Network Data Security Management Regulations adds an administrative-regulation basis for training-data security

    Interim Measures for the Management of Generative AI Services

  5. 2025-02-12

    Promulgated as CAC Order No. 18 (the cac.gov.cn page carries a publication date of 14 Feb 2025)

    Measures for the Administration of Personal Information Protection Compliance Audits

  6. 2025-02-28

    Mandatory national standard GB 45438-2025 “Cybersecurity technology — Labeling method for content generated by artificial intelligence” is issued

    Measures for Labelling AI-Generated and Synthetic Content

  7. 2025-03-14

    The four departments issue the Labelling Measures

    Measures for Labelling AI-Generated and Synthetic Content

  8. 2025-05-01

    PI Protection Compliance Audit Measures take effect

    Personal Information Protection Law

  9. 2025-05-01

    Art. 20: the Measures take effect

    Measures for the Administration of Personal Information Protection Compliance Audits

  10. 2025-07-21

    Adopted at the CAC’s 17th administrative meeting of 2025 and agreed by SAMR

    Measures on Certification for Outbound Transfer of Personal Information

  11. 2025-09-01

    AI Content Labelling Measures and GB 45438-2025 take effect, giving Art. 12 concrete content

    Interim Measures for the Management of Generative AI Services

  12. 2025-09-01

    AI Content Labelling Measures give operational detail to Arts. 16 and 17

    Provisions on the Administration of Deep Synthesis in Internet Information Services

  13. 2025-09-01

    The Labelling Measures and GB 45438-2025 take effect on the same day

    Measures for Labelling AI-Generated and Synthetic Content

  14. 2025-10-28

    NPC Standing Committee adopts the amending decision, adding an AI article and sharply raising penalties

    Cybersecurity Law

  15. 2026-01-01

    Measures take effect, completing the third outbound route

    Measures on Certification for Outbound Transfer of Personal Information

  16. 2026-08-20

    The Network Data Security Risk Assessment Measures (Order No. 24) take effect, operationalising the Art. 30 periodic risk assessment

    Data Security Law

Applicable regulations (20)

In forceData & privacyRelevance Critical

Personal Information Protection Law

Three business actions pull a Chinese AI company into scope: (1) processing any natural person’s personal information inside the PRC (Art. 3 §1), including training models on user conversations, faces, voices or driving data; (2) processing outside the PRC where the purpose is to offer products or services to individuals in China, or to analyse or evaluate their behaviour (Art. 3 §2) — for example running Chinese app data on a Singapore node; and (3) sending personal information collected in China to an offshore affiliate, cloud vendor or customer (Art. 38), which is the most common trigger for outbound-facing businesses. Art. 53 additionally requires a purely offshore processor to establish a dedicated PRC entity or appoint a PRC representative.

7 obligations · reviewed 2026-09-12

In forceCybersecurityRelevance Critical

Data Security Law

Four business actions trigger this law: (1) carrying out any data processing inside the PRC (Art. 2 §1), including collecting, cleaning, storing and sharing training corpora; (2) offshore processing that harms PRC national security, the public interest, or the lawful rights of PRC citizens and organisations (Art. 2 §2); (3) having your operational data listed as important data by your sector regulator — high-definition maps and road or plant-environment captures from embodied-AI and autonomous-driving companies are prime candidates; and (4) an offshore customer, parent company or foreign regulator demanding data stored in China (Art. 36), which arises routinely in US or EU discovery, FCPA investigations and listing audits.

5 obligations · reviewed 2026-09-12

AmendedCybersecurityRelevance High

Cybersecurity Law

It applies to anyone building, operating, maintaining or using networks inside the PRC (Art. 2). Concrete triggers for AI companies: hosting a model service on domestic cloud makes you a network operator, requiring MLPS grading and filing plus retention of network logs for at least six months; offering users information-publishing or instant-messaging features — including the community and sharing functions inside conversational products — requires real-name authentication; selling AI appliances or robot controllers that fall within the catalogue of critical network equipment or dedicated cybersecurity products requires certification or testing before sale; and being designated a CIIO, or supplying one, brings procured network products and services that may affect national security within the cybersecurity review.

5 obligations · reviewed 2026-09-12

In forceData & privacyRelevance Critical

Regulations on Network Data Security Management

It applies to network data processing carried out inside the PRC (Art. 2). Concrete triggers for AI companies: crawling and cleaning training corpora (Art. 18 requires an impact assessment for automated collection tools and prohibits interfering with others’ network services); sending user conversations and facial images to offshore annotation vendors (the contract and three-year record duties in Art. 12); routing user input to an offshore model through an API (Art. 35); and the organisational requirements that bite once the user base crosses 10 million individuals (Arts. 28 and 30). An entity registered offshore that serves individuals in China is likewise caught by Art. 2 §2.

7 obligations · reviewed 2026-09-12

In forceCross-border dataRelevance Critical

Measures for Security Assessment of Outbound Data Transfers

Three actions force this route: (1) once designated a CIIO, transferring any personal information or important data abroad — for example deploying on-site for energy, transport or financial customers and sending operating data back; (2) transferring important data abroad, such as sending high-definition maps, plant point clouds or roadside perception data to an offshore R&D centre; and (3) as a non-CIIO, cumulatively transferring since 1 January of the current year the personal information of more than 1 million individuals (excluding sensitive data) or the sensitive personal information of more than 10,000 individuals — for example a China-facing app syncing user profiles and facial features to an offshore headquarters.

4 obligations · reviewed 2026-09-12

In forceCross-border dataRelevance Critical

Measures on the Standard Contract for Outbound Transfer of Personal Information

It applies where all four conditions in Art. 4 are met: (1) the exporter is not a CIIO; (2) it processes the personal information of fewer than 1 million individuals; (3) it has cumulatively transferred abroad the personal information of fewer than 100,000 individuals since 1 January of the preceding year; and (4) it has cumulatively transferred abroad the sensitive personal information of fewer than 10,000 individuals over the same period. Limbs (3) and (4) are restated by Art. 8 of the Cross-border Data Flow Provisions as “at least 100,000 but fewer than 1 million individuals’ personal information (excluding sensitive data), or fewer than 10,000 individuals’ sensitive personal information, counted cumulatively from 1 January of the current year”, and that formulation governs. These Measures cover outbound transfers of personal information only (Art. 2); important data always goes through the security assessment. Typical business actions: a China SaaS syncing customer contacts into an offshore CRM; a cross-border retailer passing Chinese consumers’ order data to overseas warehouses and payment providers; an outbound app using offshore analytics and push services; and reporting Chinese employees’ HR records into an offshore group HR system where the pure HR-management exemption does not apply.

4 obligations · reviewed 2026-09-12

In forceCross-border dataRelevance High

Measures on Certification for Outbound Transfer of Personal Information

The applicable band is the same as for the standard contract: a non-CIIO that has cumulatively transferred, since 1 January of the current year, the personal information of at least 100,000 but fewer than 1 million individuals (excluding sensitive data), or the sensitive personal information of fewer than 10,000 individuals, may choose certification instead of the standard contract. It is worth most to three kinds of Chinese AI company: (1) groups with many entities and many transfer flows, where one certification can cover a family of intra-group transfers instead of a contract per pair; (2) B2B vendors that need to demonstrate data-governance maturity to offshore enterprise customers, since the certificate drops straight into a due-diligence pack; and (3) platform businesses whose transfer flows change often, making per-transfer filing uneconomic.

3 obligations · reviewed 2026-09-12

In forceCross-border dataRelevance Critical

Provisions on Promoting and Regulating Cross-border Data Flows

Any action that moves data out of China must clear this gate first. Four determinations matter most to Chinese AI companies: (1) calling an offshore model API or running inference on offshore cloud — where user input contains personal information, the cumulative headcount places the transfer in the standard-contract/certification band or the assessment band; (2) cross-border HR management — where it is carried out under lawfully adopted labour rules and a lawfully concluded collective contract, employee personal information may be exempt under Art. 5(2); (3) cross-border retail, flight and hotel booking and cross-border payments, where the transfer is necessary to conclude or perform a contract to which the individual is a party, exempt under Art. 5(1); and (4) purely offshore business data brought into China for algorithmic processing and sent back out, exempt under Art. 4 provided no domestic personal information or important data is introduced — the key basis for the “onshore R&D centre serving overseas markets” architecture.

5 obligations · reviewed 2026-09-12

In forceAI regulationRelevance Critical

Interim Measures for the Management of Generative AI Services

Applicability turns on two questions only: is the technology generative, and is the service offered to the public within the PRC. Four actions fall in: (1) opening a self-trained or open-source-fine-tuned model to the public in China, whether as an app, a website or an API; (2) supplying a programmable interface to Chinese enterprise customers who then serve consumers — the interface provider is itself a provider; (3) an offshore company supplying a generative service into China through domestic channels (Art. 20); and (4) research and development of generative technology by industry bodies, enterprises, and educational or research institutions that does not involve offering a service to the public in China, which Art. 2 §3 places outside these Measures — the key boundary for the “launch offshore, keep only R&D onshore” architecture, though that architecture remains subject to the data, export-control and science-and-technology ethics rules.

7 obligations · reviewed 2026-09-12

In forceAI regulationRelevance Critical

Provisions on the Administration of Deep Synthesis in Internet Information Services

It applies to anyone applying deep synthesis technology to provide internet information services inside China (Art. 2). For Chinese AI companies the reach is wider than “generative AI”: intelligent dialogue and writing, TTS and voice cloning, digital humans and virtual presenters, face editing and face swapping, AI photo retouching and quality enhancement, and 3D reconstruction and metaverse scenes are all within the Art. 23 list. The technical-supporter role is easily overlooked: a company supplying digital-human SDKs, voice-cloning APIs or image-generation base models to customers carries the training-data management duty (Art. 14) and the periodic algorithm review and validation duty (Art. 15) even without any consumer-facing product.

6 obligations · reviewed 2026-09-12

In forceAI regulationRelevance Critical

Provisions on the Administration of Algorithmic Recommendation in Internet Information Services

The scope is broader than intuition suggests: Art. 2 §2 defines “applying algorithmic recommendation technology” in the operative text itself as “using generative and synthetic, personalised push, ranking and selection, retrieval and filtering, or scheduling and decision algorithms to provide information to users” — all five families are named in the rule. Concrete triggers for Chinese AI companies: (1) serving personalised content or product recommendations to users in China; (2) providing generative AI services with public-opinion attributes or social-mobilisation capability, which Art. 17 of the Generative AI Interim Measures routes into filing under these Provisions; (3) providing deep synthesis services with those attributes, routed in by Art. 19 of the Deep Synthesis Provisions; and (4) using algorithms to dispatch work to labourers (Art. 20) or to sell goods and services to consumers (Art. 21), which brings delivery-dispatch and dynamic-pricing AI into scope.

6 obligations · reviewed 2026-09-12

In forceAI regulationRelevance Critical

Measures for Labelling AI-Generated and Synthetic Content

Art. 2 defines the scope by cross-reference to three departmental rules, which in practice covers almost every Chinese AI company offering generative capability to the public in China. Four roles carry distinct duties: (1) the generating provider must add the explicit label under Art. 4 and the implicit metadata label under Art. 5, and must ensure downloaded, copied or exported files still carry a conforming explicit label; (2) the dissemination platform must verify the implicit metadata label under Art. 6 and add differently worded prompts in three situations (metadata confirms generation, the user declares it, or traces are detected), while writing dissemination metadata back into the file; (3) the app distribution platform must, under Art. 7, ask at review whether the app provides generative or synthetic services and verify its labelling materials; and (4) users must, under Art. 10, declare and apply the provider’s labelling function when publishing.

5 obligations · reviewed 2026-09-12

In forceAI regulationRelevance High

Measures for Science and Technology Ethics Review (for Trial Implementation)

Three direct triggers for Chinese AI companies come from the annexed list. Item 5, “research and development of human-machine integrated systems with a strong influence on human subjective behaviour, psychological emotions and life and health”, covers brain-computer interfaces and emotional-companionship and psychological-intervention products. Item 6, “research and development of algorithmic models, applications and systems with the capability to mobilise public opinion and society and to guide social consciousness”, covers public-facing large models and content recommendation systems. Item 7, “research and development of highly autonomous automated decision systems for scenarios involving safety or personal-health risks”, covers autonomous driving, surgical robots and industrial and inspection robots. Separately, any use of personal information data, or of humans as test, survey or observation subjects (Art. 2(1)), requires internal ethics review — common in model evaluation, user research and data collection.

4 obligations · reviewed 2026-09-12

In forceExport controlsRelevance Critical

Export Control Law

For Chinese AI companies the reach extends well beyond shipping hardware abroad. Four actions need separate analysis: (1) transferring technical data abroad — model weights, training code, algorithm descriptions, test datasets and chip design files can all constitute “technical data and other data relating to the items” under Art. 2 §2; (2) providing controlled items to foreign organisations and individuals, which includes disclosing controlled technology inside China to foreign-national employees, foreign partner teams or foreign shareholders (a deemed export), something that happens readily in cross-border R&D collaboration and due diligence; (3) exporting goods, technologies and services that are not listed but where the exporter “knows or should know” they may endanger national security and interests or be used for weapons of mass destruction or terrorism, which requires a licence under Art. 12 §3; and (4) transacting with importers or end users on the control list (Art. 18 §3), which requires prior screening.

4 obligations · reviewed 2026-09-12

In forceExport controlsRelevance Critical

Regulations on Export Control of Dual-Use Items

Four typical triggers for Chinese AI and embodied-intelligence companies: (1) exporting listed dual-use items such as AI accelerator cards, high-performance computing modules, specified sensors and unmanned-system components; (2) exporting related technology and services, since the Regulations adopt the Export Control Law’s definition of controlled items, under which technical data is likewise controlled; (3) the extraterritorial reach of Art. 49, under which MOFCOM may require operators to follow the Regulations for dual-use items made abroad using specified Chinese-origin technology, or containing specified Chinese-origin dual-use items, when transferred to specified destinations — directly affecting “develop in China, manufacture offshore, sell to a third country” supply chains; and (4) the blocking duty in Art. 38, under which a request by an offshore customer, investor or foreign government for an on-site export-control compliance inspection of a PRC factory or laboratory must first be reported to MOFCOM.

5 obligations · reviewed 2026-09-12

In forceExport controlsRelevance High

Technology export administration: the prohibited/restricted technology Catalogue and the Technology Import and Export Regulations

Three actions by Chinese AI companies need individual assessment: (1) providing algorithms, models or core technology to an offshore entity through patent licensing, transfer of know-how, technical cooperation or technical services; (2) setting up an offshore R&D entity or joint venture and transferring existing domestic technology into it — the step most often missed when technology is contributed as capital or equity; and (3) injecting domestic technology assets into an offshore holding entity during an outbound restructuring. The determination turns on the Catalogue entries themselves: the Catalogue is organised by sector and states control points for restricted technologies, so the company’s actual technical content must be compared against the entry text rather than inferred from a product name or sector label. NOTE, however, that the version described here — the annex to the 2008 Order No. 12 as adjusted by Announcement No. 38 of 2020 — lapsed with that Order on 21 Dec 2023, so the comparison must be run against MOFCOM’s currently published Catalogue and not against the version described in this record. Where a military-civil dual-use character is present, the Export Control Law and the Dual-Use Items Regulations must be applied in parallel.

4 obligations · reviewed 2026-09-12

In forceCybersecurityRelevance High

Regulations on the Security Protection of Critical Information Infrastructure

Two quite different routes apply to Chinese AI companies, and almost all of them travel the second. Route one (rare): the company is itself identified as a CII operator. That happens only where its network facilities or information systems carry the critical core business of an important sector — public communications and information services, energy, transport, water conservancy, finance, public services, e-government, the defence science and technology industry — and the sector’s protection department identifies it against the identification rules and notifies it in writing. A company cannot self-identify as CII, nor escape liability by deciding it is not one: the determination belongs to the protection department and the operative fact is that notice. Route two (common): as a supplier or service provider to a CII operator, the duties come down the procurement chain. The typical setting is selling a foundation-model platform, an intelligent service agent, visual inspection, a data platform or AI operations tooling to power, transport, financial or government customers, at which point the customer writes Arts. 19 and 20 into the contract: procurement that may affect national security must pass cybersecurity review (the supplier has to provide materials and explain its supply chain and data flows); a security and confidentiality agreement must be signed setting out the term of technical support and the supplier’s confidentiality obligations and liabilities, subject to supervision; and products and services must meet the “secure and trustworthy” standard. Art. 15(7) brings design, construction, operation and maintenance services within the operator’s security management, which means the supplier’s implementation and operations teams fall under the customer’s security management and appraisal. Art. 31 applies to every company besides: teams building security-testing, red-team, automated penetration or vulnerability-scanning AI products may not probe or penetration-test CII without approval or authorisation, so the product’s default scanning scope and its demo environments need hard boundaries.

5 obligations · reviewed 2026-09-12

In forceData & privacyRelevance High

Measures for the Administration of Personal Information Protection Compliance Audits

The starting point is the scale of processing in China, not where the company is registered or whether its market is offshore — Art. 2 frames the scope as “carrying out personal information protection compliance audits within the PRC”. Three situations catch Chinese AI companies most often. (1) THE USER THRESHOLD ARRIVES FASTER THAN THE COMPLIANCE CADENCE. Consumer-facing chat assistants, AI cameras, companion and education apps often need only one growth cycle to pass 10 million registered users, after which a compliance audit at least every two years is a fixed cadence rather than a when-we-get-to-it item; and the count is of individuals whose personal information is processed — including dormant users, deactivated accounts whose data is still retained, and end users reached through an SDK or entrusted processing — a much wider figure than DAU. (2) A SECURITY INCIDENT CONVERTS A SELF-AUDIT INTO A MANDATED ONE. A single incident leaking more than 1 million individuals’ personal information or more than 100,000 individuals’ sensitive personal information is enough to trigger Art. 5(3), after which the choice of institution, the deadline, the cost, and the report and remediation filings all follow the protection department’s instructions. (3) THE AUDIT SCOPE POINTS STRAIGHT AT THE WEAK SPOTS OF AN AI BUSINESS. The Guidelines’ review points on automated-decision transparency and the right to refuse, separate consent for sensitive personal information, guardian consent for minors under 14, outbound transfer routes, giving effect to deletion, and impact assessments land exactly where a model training and inference pipeline is hardest to evidence: the lawful basis for training corpora, retention and deletion of conversation logs, whether personal information in models and logs can actually be deleted, and explanations of automated decisions in recommendation and risk control. Beyond the regulator, offshore customers and investors increasingly treat this audit report as direct evidence of China-side data compliance, so an outbound-focused company still has to run the audit for its PRC entity.

5 obligations · reviewed 2026-09-12

In forceSector-specificRelevance High

China pilot for market access and road operation of intelligent connected vehicles

A Chinese company is caught when it intends to mass-produce and sell vehicles with L3/L4 automated driving in China, which requires entering the pilot to obtain product access rather than following the ordinary type access route; when it forms a consortium with a vehicle manufacturer as the user entity for robotaxi, driverless shuttle or trunk logistics operations, thereby taking primary responsibility for road traffic safety, cybersecurity and data security; and when, as an automated driving system supplier, its software updates and functional changes fall under the manufacturer duty not to change automated driving functions without authorisation and to comply strictly with software update management and filing commitments. For companies going abroad this is the natural starting point for dual-tracking domestic safety assessment evidence with UN R155/R156/R157 or EU ADS evidence packages.

5 obligations · reviewed 2026-09-12

In forceSector-specificRelevance Critical

Several Provisions on Automotive Data Security Management (Trial)

A Chinese AI company is caught when its automated driving or smart cockpit team collects road video, point clouds or cabin audio and video in China for model training, since off-vehicle video and images containing faces or licence plates are important data; when its user base passes 100,000 personal information subjects, which makes that personal information important data; when it transfers Chinese road test data, scenario catalogues or cabin data to an overseas R&D centre, overseas cloud or foreign partner, which first requires the security assessment organised by the national cyberspace department together with the relevant State Council departments; and when, as a component or software supplier or a mobility service company, it processes automotive data for a vehicle manufacturer, since it is itself an automotive data processor under these Provisions. The classic exposure for companies going abroad is sending Chinese road data overseas for training, and mixing returned overseas fleet data with Chinese data inside China.

6 obligations · reviewed 2026-09-12

Data transfer routes

  • Security assessment filing for outbound data transfers (CAC Order No. 11 as modified by Order No. 16)

    Under Art. 7 of Order No. 16 a security assessment must be filed where: (1) a critical information infrastructure operator (CIIO) provides personal information or important data abroad; or (2) a non-CIIO data handler provides important data abroad, or has cumulatively provided abroad, since 1 January of the current year, the personal information of more than 1,000,000 individuals (excluding sensitive personal information) or the sensitive personal information of more than 10,000 individuals. Where Arts. 3, 4, 5 or 6 of Order No. 16 apply, those provisions govern first (exemptions and the free-trade-zone negative list). Two points must be got right: (1) the count runs "cumulatively from 1 January of the current year", replacing the "from 1 January of the previous year" wording in Art. 4 of Order No. 11; (2) important data is identified under Art. 2 of Order No. 16 and Art. 37 of the Network Data Security Management Regulations - if no department or region has notified or publicly published the data as important data, the handler need not file it as such.

    Lead time: Estimate: the statutory steps total roughly 57 working days (5 for the provincial completeness check, 7 for the national acceptance decision, 45 for the assessment, extendable). Adding the self-assessment, negotiation of the legal document and package preparation, 4-8 months from kick-off to outcome is typical in practice, and a returned package lengthens it materially. · Cost band Very High

  • Filing of the China standard contract for outbound personal information transfers (CAC Order No. 13 as modified by Order No. 16)

    Under Art. 8 of Order No. 16: a non-CIIO data handler that has cumulatively provided abroad, since 1 January of the current year, the personal information of 100,000 or more but fewer than 1,000,000 individuals (excluding sensitive personal information), or the sensitive personal information of fewer than 10,000 individuals, must either conclude the standard contract with the overseas recipient or obtain personal information protection certification. Where Arts. 3, 4, 5 or 6 of Order No. 16 apply, those provisions govern. Art. 4 of Order No. 13 originally set four cumulative conditions (non-CIIO; processing the personal information of fewer than 1,000,000 individuals; fewer than 100,000 individuals’ personal information transferred abroad cumulatively since 1 January of the previous year; fewer than 10,000 individuals’ sensitive personal information on the same count); to the extent these conflict with Order No. 16, Art. 13 of Order No. 16 makes Order No. 16 prevail. Splitting volumes to avoid the security assessment is expressly prohibited by the final paragraph of Art. 4 of Order No. 13. Terminology note: the alternative option in Art. 8 of Order No. 16, "obtain personal information protection certification", has since 1 Jan 2026 been governed by its own instrument, the Measures for Personal Information Outbound Transfer Certification (CAC and SAMR Order No. 20), and the official term is now "personal information outbound transfer certification" - see the corresponding entry in this matrix.

    Lead time: Estimate: 3-6 weeks for the impact assessment and contract negotiation; the filing itself is due within 10 working days of the contract taking effect. Provinces differ in formal requirements and response pace, and in practice feedback or a request to supplement typically arrives 2-8 weeks after submission. · Cost band Medium

  • China personal information outbound transfer certification (CAC and SAMR Order No. 20, in force 1 Jan 2026)

    The volume band matches the standard contract and is restated independently in Art. 5 of Order No. 20: a handler using certification to provide personal information abroad must satisfy both (1) it is not a CIIO; and (2) it has cumulatively provided abroad, since 1 January of the current year, the personal information of 100,000 or more but fewer than 1,000,000 individuals (excluding sensitive personal information), or the sensitive personal information of fewer than 10,000 individuals. Art. 5(2) states that the personal information referred to does not include important data; Art. 5(4) prohibits splitting volumes to divert to certification data that must go through the security assessment. Certification cannot substitute for the assessment once the Art. 7 thresholds of Order No. 16 are met. Two practical points from the CAC Q&A of September 2026: (1) a handler of any size may voluntarily apply to a professional body for certification to demonstrate and improve compliance, but only a handler inside the Art. 5 band may rely on certification as the legal basis for the transfer; (2) a certified handler whose cumulative outbound volume reaches 1,000,000 individuals’ personal information or 10,000 individuals’ sensitive personal information must still file a security assessment, and may attach its certification record for the authorities to take into account. Selection rule of thumb: certification suits groups with many entities, many routes and permanent flows, because one certificate can cover multiple processing activities within its scope; a single counterparty on a single route is better served by the standard contract.

    Lead time: Estimate: 3-6 months from engagement to certificate (technical verification and the on-site audit take weeks each, and rectification rounds extend this). Neither Order No. 20 nor the Implementation Rules sets a uniform statutory turnaround; they require the body to define and meet time limits for each stage. The fixed deadlines in Order No. 20 fall on the body and the regulator (a body must file within 10 working days of qualifying, the CAC reviews within 30 working days, certificate information is reported within 5 working days). The real timeline depends on the chosen body’s implementation rules and the applicant’s responsiveness. · Cost band High

  • China outbound transfer exemptions and volume thresholds (Arts. 3-5, CAC Order No. 16)

    The volume ladder, which must be read together with the assessment and standard-contract thresholds: for a non-CIIO, personal information (excluding sensitive personal information) provided abroad cumulatively since 1 January of the current year for fewer than 100,000 individuals is fully exempt; 100,000 or more but fewer than 1,000,000 requires the standard contract or certification; 1,000,000 or more requires the security assessment. Sensitive personal information is counted separately: fewer than 10,000 individuals requires the standard contract or certification; 10,000 or more requires the security assessment. CIIOs need care here: on its wording the 100,000-person exemption in Art. 5(4) is given only to "data handlers other than critical information infrastructure operators", so a CIIO cannot invoke it; at the same time the closing paragraph of Art. 7 of Order No. 16 provides that "where Arts. 3, 4, 5 or 6 of these Provisions apply, those provisions govern", and Arts. 3, 4, 5(1)-(3) and 6 do not on their face exclude CIIOs. But a CIIO providing personal information or important data abroad is the express filing trigger in Art. 7(1) and supervision is strict in practice, so a CIIO intending to rely on any of those exemptions should clear it with the competent cyberspace authority rather than decide alone. Three traps: (1) the count runs cumulatively from 1 January of the current year and resets each year - it is not a rolling 12 months; (2) the exemption removes the transfer mechanism only, not the PIPL duties - Art. 10 of Order No. 16 expressly requires notice, separate consent and a personal information protection impact assessment, and Art. 11 still requires data security duties and reporting of actual or potential data security incidents to the provincial or higher cyberspace authority; (3) sensitive personal information is outside Art. 5(4), whose text expressly excludes it.

    Lead time: Estimate: 2-4 weeks to build the ledger, fix the counting convention and produce the exemption memorandum; there is no approval step. · Cost band Low

  • Free trade zone data export negative list (Art. 6, CAC Order No. 16)

    The route applies only where both the handler and the data fall within a free trade zone that has published an approved and filed negative list. Volume thresholds are set by each zone in its own list, typically layered by industry and data category and sometimes with headcount or volume cut-offs, so there is no nationwide numeric threshold - the current list text must be checked zone by zone and catalogue by catalogue. What was verified: the mechanism and approval chain established by Art. 6 of Order No. 16 (approval by the provincial cybersecurity and informatisation commission, then filing with the national cyberspace authority and the national data authority); and that zones do publish formal negative lists, verified on one example - the notice of the Beijing cyberspace administration and two other departments issuing the Beijing FTZ data export negative list administrative measures (trial) and the 2024 negative list (Jing Wang Ban Fa [2024] No. 16, dated 26 Aug 2024, published 30 Aug 2024, marked in force on the municipal portal), with the measures and the list released as annexes. What was not verified: the individual entries, industry coverage or thresholds of any list. Versions differ by zone and are revised continuously (the CAC policy column separately lists updates for Shanghai on 29 Apr 2026, Beijing on 11 May 2026 and Guangdong on 18 May 2026, and Tianjin, Zhejiang, Jiangsu, Chongqing, Guangxi and Hainan have their own), so the Beijing 2024 list has very likely been superseded. Confidence is therefore medium: always go back to the latest list published by the target zone’s administrative committee or the local cyberspace authority.

    Lead time: Estimate: 2-4 weeks for the comparison and documentation. This pass did not verify whether individual zones impose a local registration step or its timing; where the target zone does, add its published timeline. · Cost band Low

What you can use right now

Playbooks

AI hardware and compute going global: two-way export controls, end users and model-weight transfersPre-IPO ESG and sustainability disclosure readiness for HKEX (AI issuer perspective)China-side readiness before going global: algorithm and LLM filings, content labelling and the outbound data route

Templates

Transfer Impact Assessment (TIA) — supporting Clause 14 of the EU Standard Contractual ClausesOutbound Data Transfer Risk Self-Assessment Report (per the CAC filing guide template)Personal Information Protection Impact Assessment (PIPIA) reportFiling pack for generative AI services and algorithm filing, including the security assessment reportModel CardData Card — datasheet for a training, validation or test datasetAI incident and serious incident reporting record (register plus report drafts)ISSB (IFRS S1 / S2) sustainability-related financial disclosure report outlineGreenhouse gas inventory workpaper (GHG Protocol Scope 1 / 2 / 3)Double materiality assessment workpaper (CSRD / ESRS basis)HKEX ESG report outline (Listing Rules Appendix C2, including Part D climate disclosures)Sustainability report outline for issuers on the Shanghai, Shenzhen and Beijing exchanges (aligned to the MOF Basic Standard)Customer security and privacy questionnaire answer bank (grouped by CAIQ / CCM domains)Tender / RFP compliance response pack (covering both EU public procurement and enterprise procurement)SOC 2 Type II readiness checklist (Trust Services Criteria)ISO/IEC 42001 AI management system implementation and certification readiness checklistSupplier and subcontractor ESG and security due diligence questionnaire (for use as the buyer)Investor ESG due diligence pack (for fundraising and pre-IPO)Third-party sustainability assurance readiness checklist (starting from limited assurance)

Relevant standards

  • IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information · IFRS S1 (issued June 2023; not amended as at 12 September 2026 — the December 2025 greenhouse gas emissions amendments apply only to IFRS S2)
  • IFRS S2 Climate-related Disclosures · IFRS S2 (issued June 2023; amended by the December 2025 Amendments to Greenhouse Gas Emissions Disclosures, effective for annual reporting periods beginning on or after 1 January 2027)
  • Sustainability reporting rules and preparation guides of the Shanghai, Shenzhen and Beijing stock exchanges · SSE Self-Regulatory Guideline No. 4 for Listed Companies — Preparation of Sustainability Reports (revised January 2026; Shang Zheng Han [2026] No. 484), with Application Guides No. 1 to No. 5 (mandatory)
  • Chinese Sustainability Disclosure Standards — Basic Standard (Trial) and its Application Guidance · Basic Standard (Trial), Cai Kuai [2024] No. 17; Application Guidance, Cai Kuai [2025] No. 21
  • ISO 14064-1:2018 Greenhouse gases — Specification with guidance at the organization level for quantification and reporting of greenhouse gas emissions and removals · ISO 14064-1:2018 / EN ISO 14064-1:2018
  • ISO 14067:2018 Greenhouse gases — Carbon footprint of products — Requirements and guidelines for quantification · ISO 14067:2018
  • CSA STAR and STAR for AI (including CCM, CAIQ, AICM and AI-CAIQ) · STAR program (combined CCM/CAIQ v4.1); AI Controls Matrix AICM v1 (released 2025-07-09, updated 2025-10-30; v1.1 also published)

What has actually happened here

Sources (24)

Content as of 2026-09-12 · corpus 2026.09|Compiled from public official sources with links and review dates for compliance decision support. Rules change; have licensed professionals review before external disclosure, regulatory filing or contractual commitments.

GDPR · PIPL · CCPA control mapping
Traceable AI · cited when sourced
ISO 27001 alignment in progress
WCAG 2.1 AA accessibility target
China (Mainland): compliance overview | HaiWen HQ