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
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
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
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
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
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
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
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
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
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
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 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
In Part 2 of this series, we discussed how the Personal Information Protection Law (“PIPL”), the centerpiece of China’s personal information (“PI”) protection law, needs to be read in conjunction with other relevant laws,...more
The Cyberspace Administration of China (“CAC”) on November 14, 2021 published the draft Regulations on the Administration of Network Data Security (“Draft Regulations”) for comment through December 13, 2021.1 The Draft...more
The Cyberspace Administration of China has issued draft guidance on applying for and conducting security assessments for cross-border data transfers for public comment. On October 29, 2021, the Cyberspace Administration of...more
China has recently joined the list of countries that have adopted the world’s strictest data-privacy laws. Given China’s desirability as both a market for and a source of data, companies worldwide have started making early...more