On October 28, 2025, China adopted the first major amendments to the 2017 Cybersecurity Law, which took effect on January 1, 2026. The revised Law establishes an additional tiered penalty regime featuring stricter fines for...more
Cross-border investigations are rarely straightforward. Legal obligations vary by country, and cultural expectations can shape both access and cooperation. By the time counsel gets involved, the investigation is already...more
On December 29, 2025, the Cyberspace Administration of China ("CAC") officially released the Notice on the Filing of Compliance Audit Results for the Protection of Minors’ Personal Information ("Filing Notice")....more
On December 6 2025, the CAC released the draft Network Data Security Risk Assessment Measures (Draft for Comments) for public consultation. The measures aim to standardize network data security risk assessment activities,...more
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
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
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
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
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
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
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
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
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
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
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
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
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
The newly promulgated measures increase the threshold of data triggering security assessments and contract requirements while leaving room for Chinese authorities to heavily restrict cross-border data transfers. In...more
Multinational employers operating in China have been waiting since September 2023 for the Cyberspace Administration of China (CAC) to finalize proposed revisions to its complex and burdensome rules for cross-border data...more
China is seeking to take a significant step to relax the compliance burden on multinational corporations (MNCs) regarding data export from China by allowing: (i) certain routine data exports for daily business operation or...more
The Cyberspace Administration of China (“CAC”) on September 28, 2023 issued the draft Provisions on the Regulation and Promotion of Cross-Border Data Flows (“draft Provisions”), just one year after China’s data export...more
U.S.-based multinationals with employees in the People’s Republic of China (PRC) are confronting a November 30 deadline to implement China’s new cross-border data transfer mechanism—the Standard Contract. This implementation...more
China’s stance toward data privacy and cybersecurity has been a matter of interest for the last several years, most prominently with the June 2017 passage of China’s Cybersecurity Law, and the passage of the Data Security Law...more
On June 29, 2023, the Cyberspace Administration of China ("CAC") and the Innovation, Technology and Industry Bureau of the Hong Kong Special Administrative Region ("Hong Kong") Government ("HKITIB") signed the Memorandum of...more
On 30 May 2023, the Cyberspace Administration of China (the “CAC”) published guidance for the use of the Standard Contractual Clauses applicable to international transfers of personal information from mainland China (the...more