News & Analysis as of

Personal Information Protection Law (PIPL)

Hogan Lovells

China announces audit reporting requirements for minors’ data

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On December 29, 2025, the Cyberspace Administration of China (CAC) issued the Announcement on the Reporting of Minors' Personal Information Protection Compliance Audit Status, which requires personal information handlers to...more

DLA Piper

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

DLA Piper on

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...more

Dacheng

China Monthly Data Protection Update - December 2025

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This monthly report outlines key developments in China’s data protection sector for December. The following events merit special attention: On November 22, CAC and the MPS jointly released the Provisions on the Protection of...more

Hogan Lovells

China PIPO reporting obligation: Post-implementation practical guidelines & compliance checklist

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On 18 July 2025, the Cyberspace Administration of China (“CAC”) issued the Announcement on the Reporting of Personal Information Protection Officer Information (“CAC PIPO Reporting Announcement”), which launched a centralized...more

Dacheng

First Cross-Border PI Transfer Penalty Highlights Necessity of Tailoring Data Compliance Frameworks in China

Dacheng on

On September 9, 2025, Dior (Shanghai) Co., Ltd. (“Dior Shanghai”) was publicly sanctioned in China for unlawfully transferring personal information (“PI”) overseas. This marks the first administrative penalty in China for...more

Dacheng

China Issues First Administrative Penalty for Unlawful Cross Border Transfer of Personal Information

Dacheng on

On September 9, 2025, China announced the landmark administrative penalty against Dior (Shanghai) over unlawful cross-border transfers of personal information, with the primary violation being the failure to satisfy the...more

Morgan Lewis

China’s New Standard on Sensitive Personal Information Goes Into Effect November 1

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In a move to further bolster data privacy, China’s State Administration for Market Regulation and the Standardization Administration of China jointly issued a national standard, GB/T 45574-2025, Data Security Technology –...more

K&L Gates LLP

China’s New DPO Registration Requirement: What You Need to Know

K&L Gates LLP on

On 18 July 2025, China’s Cyberspace Administration (CAC) officially launched its online portal (Portal) for registration of China Data Protection Officers (China DPO). This operationalizes the requirements under Article 52 of...more

Dacheng

China Monthly Data Protection Update: August 2025

Dacheng on

This monthly report outlines key developments in China’s data protection sector for August. The following events merit special attention: CAC Summons NVIDIA Over Cybersecurity Concerns Related to H20 Chip: On July 31, CAC...more

Mayer Brown

China Proposes Amendments to the Cybersecurity Law

Mayer Brown on

INTRODUCTION - Almost eight years after the Cybersecurity Law (“CSL”) came into force in the PRC in 2017, the Cyberspace Administration of China (“CAC”) issued draft amendments to the CSL (“2025 Draft Amendments”) on 28...more

Sheppard Mullin Richter & Hampton LLP

China Initiates Mandatory Reporting Regime for Personal Information Protection Officers

On July 18, 2025, the Cyberspace Administration of China (the “CAC”) issued the Notice on Launching the Reporting Mechanism for Personal Information Protection Officers (the “Notice ”). This development marks a significant...more

Dacheng

Cross-Border Data Processing under the "Offshore Model": China's Regulatory Approach in Comparative Context

Dacheng on

As the digital economy continues to thrive and remote work becomes increasingly mainstream, an “offshore model” of business operation has emerged. Under this model, companies may provide services to users in a given...more

Dacheng

China’s First Judicial Decision on Cross-Border Personal Information Transfers: Clarification on Data Localization Requirement

Dacheng on

In August 2024, China Judgements Online published a ruling issued by the Guangzhou Internet Court on September 8, 2023, in a case widely regarded as China’s first judicial decision addressing cross-border personal information...more

Dacheng

A Practical Review of China's Restrictions on Cross-Border Transfer of Personal Information: Developments and Framework

Dacheng on

The cross-border transfer of personal information (hereinafter referred to as “PI,” and such transfers as “PI export”) is a routine and often essential part of business operations for companies in China—particularly...more

DLA Piper

CHINA: Mandatory Data Protection Compliance Audits from 1 May 2025

DLA Piper on

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...more

Mayer Brown

Guangzhou Internet Court issues the first decision on cross-border transfer of personal data under PIPL

Mayer Brown on

The Guangzhou Internet Court (the “Court”) recently issued its first judgment involving the cross-border transfer of personal data under the Personal Information Protection Law (“PIPL”).1 An international hotel group was...more

Mayer Brown

PRC Guidelines on Identifying Sensitive Personal Information

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The PRC National Technical Committee 260 on Cybersecurity of SAC (“TC260”) published new Guidelines on Identifying Sensitive Personal Information (“Guidelines”) on 18 September 2024, nearly three months after it released the...more

Morgan Lewis

Chinese Court Concluded Landmark Case on Cross-Border Transfer of Personal Information

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The Guangzhou Internet Court released the first ruling interpreting the requirements for cross-border transfer of personal information under the Personal Information Protection Law (PIPL). This case has significant...more

Cooley LLP

China Issues Network Data Security Management Regulations

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On September 30, 2024, China’s State Council released the Network Data Security Management Regulations, which will enter into force on January 1, 2025. The regulations apply to “electronic data processed and generated through...more

DLA Piper

CHINA: Enhanced and Clarified Data Compliance Obligations on Handlers of “Network Data”, Covering Personal Information and...

DLA Piper on

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...more

Morgan Lewis

China Publishes Finalized Regulation for Administration of Network Data Security

Morgan Lewis on

China published the finalized Regulation for the Administration of Network Data Security (Network Data Regulation) on September 30, 2024. This regulation was first released as a draft version dated November 2021. Throughout...more

DLA Piper

CHINA: Mandatory Data Protection Compliance (Self) Audits on Their Way

DLA Piper on

The Personal Information Protection Law (“PIPL“) requires a data controller to conduct compliance audits of its personal data processing activities on a regular basis (“Self-supervision Audits“). Apart from such...more

DLA Piper

China: Important New Guidance on Defining Sensitive Personal Information

DLA Piper on

While the definition of sensitive personal information in China has always been different to other jurisdictions, with a focus on risk of harm at its heart, new draft guidance should make it easier for organisations to map...more

Latham & Watkins LLP

China Finalises Exemptions to Cross-Border Data Transfer Rules and Eases Restrictions

Latham & Watkins LLP on

On 22 March 2024, the CAC published the final version of the Provisions on Promoting and Regulating Cross-Border Data Flows which took effect immediately and follows the draft published for consultation in September 2023. On...more

WilmerHale

Navigating China’s Data Security Laws in US Discovery

WilmerHale on

The enactment of China’s Cybersecurity Law (CSL), Data Security Law (DSL), and Personal Information Protection Law (PIPL, together with the CSL and the DSL, “Data Security Laws”) has significantly reshaped the landscape of...more

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