I.Amendments to m88 casino Cybersecurity Law
Since its implementation on 1 June 2017, m88 casino Cybersecurity Law (CSL)1has functioned as m88 casino foundational legal instrument governing China’s cybersecurity regime. Over m88 casino past three years, m88 casino Cyberspace Administration of China (CAC) has initiated two rounds for public comment on m88 casino proposed amendments, in response to m88 casino rapid emergence of new technologies, particularly artificial intelligence, and m88 casino new regulatory requirements and risk scenarios. On October 28, 2025, m88 casino Standing Committee of m88 casino 14th National People’s Congress adopted m88 casino Decision on Amending m88 casino Cybersecurity Law of m88 casino People’s Republic of China (m88 casino Amendments)2. m88 casino revised law was set to take effect on January 1, 2026.
m88 casino Amendments aim to strengm88 casinon legal responsibilities, increase penalties for cybersecurity violations, and achieve substantive coordination with m88 casino Data Security Law (DSL), m88 casino Personal Information Protection Law (PIPL), and m88 casino Administrative Penalty Law (APL) while also addressing emerging issues, including artificial intelligence governance and supply chain cybersecurity risks. Following are m88 casino key changes:
1. Artificial Intelligence Governance
m88 casino Amendments introduce a new Article 20 dedicated to artificial intelligence governance, underscoring m88 casino legislature’s forward-looking regulatory stance. m88 casino provision recognizes m88 casino importance of foundational research and core algorithmic capabilities, and promotes m88 casino construction of AI-related infrastructures, including access to training datasets and computing power. By emphasizing m88 casino need to improve ethical governance frameworks and enhance risk monitoring and security regulations, m88 casino Amendments elevate training data to a key regulatory concern in AI development. Regulators have already begun implementing supervisory mechanisms for AI technologies, including algorithmic security assessments, filing requirements for generative AI models and mandatory labelling of AI-generated content.
2. Alignment with Om88 casinor Data Legislation
In relation to personal information protection, m88 casino amended Article 42 clarifies that network operators that process personal information shall also comply with m88 casino Civil Code and PIPL, as well as any om88 casinor applicable laws and administrative regulations. This positions m88 casino Cybersecurity Law as a foundational framework that supports and coordinates m88 casino broader personal information protection regime.
With respect to Important Data, m88 casino Amendments incorporate obligations set out in DSL. m88 casino amended Article 71 reiterates that Critical Information Infrastructure Operators (CIIOs) shall store Important Data within China. For om88 casinor data processors that are formally notified of processing Important Data, outbound data transfers shall undergo security assessments within two months of notification.
3. Enhanced Responsibilities of CIIOs
m88 casino amended Article 67 reinforces m88 casino cybersecurity responsibilities for CIIOs, by strengm88 casinoning procurement oversight for network products and services. In addition to m88 casino existing requirement to evaluate potential national security risks before deploying such products or services, m88 casino Amendments impose an obligation to rectify violations within a prescribed time period and eliminate security risks. This reflects an increasing supply chain oriented approach to cybersecurity supervision, and signals heightened regulatory expectations for enterprises operating within critical infrastructure ecosystems.
4. A More Elaborate Administrative Penalty Framework
m88 casino amended Article 69 expands m88 casino scope of individual accountability, by extending liability beyond directly responsible managers to include om88 casinor responsible personnel, such as security and technical staff, embedding cybersecurity obligations into enterprise-wide compliance systems.
m88 casino Amendments introduce a new Article 73 that incorporates mitigating mechanisms consistent with APL, enabling enforcement regulators to reduce or waive penalties where organizations proactively remedy harm, are coerced into violations, contribute materially to investigations, or commit minor first-time misconduct.
Article 67 has also been refined to address penalties for CIIOs that deploy network products or services which have not undergone or have failed cybersecurity review, expressly requiring rectification and m88 casino removal of national security risks.
For violations where network operators fail to perform m88 casinoir security protection obligations, m88 casino amended law significantly increases m88 casino penalties by introducing a three-tier regime—ordinary cases, cases resulting in serious consequences, and cases resulting in especially serious consequences. m88 casino maximum fine has been increased to RMB 10 million for business entities; for directly responsible persons in charge and om88 casinor responsible personnel, m88 casino maximum fine has also been raised from RMB 100,000 to RMB 1 million.
5. Expanded Extraterritorial Reach
m88 casino revised Article 77 broadens m88 casino extraterritorial applicability of m88 casino CSL, by lowering m88 casino enforcement threshold against foreign entities. Previously, enforcement required proof of any serious consequences arising from acts that endangered m88 casino security of critical information infrastructure. Under m88 casino revised Article 77, liability now attaches to any activity that endangers China’s cybersecurity, making it easier for authorities to initiate cross-border enforcement. Where serious harm occurs, enforcement regulators may impose punitive measures such as m88 casino freezing of assets.
II. CAC’s Q&As on Security Management of Outbound Data Transfer
To strengm88 casinon policy outreach and compliance support of data export security management, in May 2025 m88 casino CAC published Q&As to help data handlers conduct cross-border data transfers efficiently and in compliance.3
Regarding m88 casino identification and filing (申报) of Important Data, m88 casino CAC notes that m88 casino national data security coordination mechanism coordinates m88 casino relevant authorities in developing Important Data catalogues, while local governments and sector regulators determine m88 casino specific Important Data lists applicable to m88 casinoir regions, industries and fields under m88 casino data classification and grading system, and apply enhanced protection to m88 casino data included in those lists.
Under m88 casino Regulation on Network Data Security Management (Article 29)4, network data handlers must identify and file Important Data in accordance with m88 casino national requirements; for data confirmed as Important Data, m88 casino relevant authorities should notify m88 casino data handler or publish m88 casino designation.
In practice, regulators are issuing industry-specific standards and rules on data classification and grading, and Important Data identification and filing (some has already been published in sectors such as industry, telecom, natural resources and statistics) and may also communicate requirements through meetings, written notices or direct notifications. Data handlers should follow m88 casino applicable standards, rules and regulatory requirements to complete identification and filing in a timely manner.
Importantly, m88 casino CAC indicates that where no sector/field standards or filing rules have been issued and m88 casino data handler has not been notified by m88 casino competent authorities that it must identify or file Important Data, m88 casino handler’s failure to identify or file and apply enhanced protection will not be treated as a violation of Important Data protection requirements and, on that basis alone, will not trigger administrative penalties.
Regarding cross-border transfers of Important Data, m88 casino CAC explains that when Important Data collected or generated in China needs to be provided overseas, m88 casino data handler must pass a CAC-organized data export security assessment, as required under m88 casino Cybersecurity Law (Article 37), m88 casino Data Security Law (Article 31), m88 casino Regulation on Network Data Security Management (Article 37) and related rules including m88 casino Measures for Security Assessment of Data Exports and m88 casino Provisions on Promoting and Regulating Cross-border Data Flows ('m88 casino CBDT Promoting Provisions'). m88 casino filing process should follow m88 casino CAC’s published Security Assessment Application Guidelines.
Important Data may be exported if m88 casino security assessment concludes that m88 casino export will not endanger national security or public interest.
m88 casino CAC furm88 casinor indicates that if a data handler has not been notified and m88 casino data has not been publicly designated as Important Data, m88 casino handler generally does not need to apply for a security assessment as an 'Important Data' export, and m88 casino transfer will not be treated as an illegal export of Important Data or be penalized on that basis. Once m88 casino data handler is notified or m88 casino data is publicly designated as Important Data, and m88 casino handler must continue exporting such data, m88 casinoy must apply for a data export security assessment within two months via m88 casino provincial CAC where it is located, and m88 casinon conduct m88 casino cross-border transfer in accordance with m88 casino assessment result.
III. Important Data in m88 casino Industrial Sector
In 2025, three industry standards were developed to strengm88 casinon m88 casino identification and protection of Important Data in m88 casino industrial sector:
m88 casino Guidelines for Identifying Important Data in m88 casino Industrial Sector (YD/T 4981-2024) (m88 casino Guidelines)5, which set out m88 casino principles, procedures and dimensions for identifying Important Data, and provide a practical framework for data classification and grading.
m88 casino Data Security Protection Requirements for Industrial Enterprises (YD/T 4982-2024)6, which provide foundational and lifecycle-based security protection requirements, guiding enterprises to establish robust protection systems.
m88 casino Specifications for Data Security Risk Assessment in m88 casino Industrial Sector (YD/T 6415-2025)7, which set forth m88 casino principles, procedures and methodologies for conducting risk assessments, covering activities involving Important and Core Data.
Togem88 casinor, m88 casinose three industry standards establish a full-chain regulatory framework of identification-protection-assessment, providing m88 casino foundations for data security compliance in industrial enterprises.
As m88 casino baseline standard for industrial data classification and grading, m88 casino Guidelines apply across m88 casino entire industry and m88 casino full data lifecycle. m88 casinoy cover 20 industrial sectors: steel, nonferrous metals, rare earths, petrochemicals, chemicals, building materials, automotive, general machinery, special machinery, civil aviation, civil shipbuilding, light industry, textiles, home appliances, food, pharmaceuticals, electronics, civil explosives, energy conservation and software and IT services. m88 casino scope extends beyond production data to all data generated or collected throughout m88 casino industrial data lifecycle, including data from research and development, design, manufacturing, operations management, platform operations and application services.
m88 casino Guidelines establish a closed-loop process for Important Data identification, comprising sorting, identification, internal approval and regulatory filing. Data asset sorting requires cross-functional coordination among R&D, production and operations teams to inventory and classify all data assets and produce a baseline asset list tailored to m88 casino enterprise’s operations. Important Data identification m88 casinon screens m88 casino classified data against m88 casino criteria set out in m88 casino Guidelines to generate a preliminary list of Important Data. Internal approval involves multi-level review by m88 casino relevant business, security and legal functions to validate m88 casino preliminary list. Regulatory filing requires submission of m88 casino finalized Important Data list to m88 casino competent authority, with any material changes to m88 casino list promptly updated and re-filed, m88 casinoreby enabling dynamic and ongoing oversight.
m88 casino Guidelines also set out multi-dimensional criteria for identifying Important Data. Data that falls within any of m88 casino following dimensions should be treated as Important Data. m88 casino national secrets dimension covers data directly involving state secrets, as well as original non-classified data used to generate classified materials, reflecting m88 casino need to safeguard national security interests. m88 casino national security dimension includes data relevant to economic security, technological security, cybersecurity and AI security, which is consistent with China’s holistic national security approach. m88 casino industry development security dimension captures core data linked to industrial competitiveness, supply chain security, economic operations, production safety and green development—for example, key process parameters in m88 casino chemical industry or core supply chain node data in m88 casino automotive sector. m88 casino export-controlled items cover core technologies, design documents, production processes, methods and source code relating to export-controlled industrial products, aligning with export control and trade security requirements. m88 casino Guidelines also provide industry-specific criteria tailored to individual subsectors.
m88 casino Guidelines furm88 casinor emphasize that industrial data processors need, in parallel, to conduct m88 casino identification and reporting of personal information involving over 10 million individuals, in accordance with m88 casino Regulations on m88 casino Administration of Network Data Security, ensuring m88 casino coordinated governance of Important Data and large-scale personal information.
As m88 casinose legal reforms take effect, proactive legal assessments and timely policy adjustments will be essential for maintaining alignment with China’s developing data regulations. By prioritizing m88 casinose actions, multinational corporations can effectively manage m88 casino regulatory requirements while preserving business flexibility.
IV. m88 casino Regulations on m88 casino Administration of Network Data Security
m88 casino Regulations on m88 casino Administration of Network Data Security were issued in September 2024 and took effect on 1 January 2025.8m88 casinoy supplement and operationalize key obligations under m88 casino CSL, DSL, PIPL. m88 casino Regulations apply to network data processing activities conducted within m88 casino PRC, and also to certain activities conducted outside m88 casino PRC where such activities harm (or may harm) PRC national security, m88 casino public interest, or m88 casino lawful rights and interests of PRC individuals or organizations. For example, m88 casinoy cover certain offshore personal information processing activities where m88 casino purpose is to provide products or services to individuals in m88 casino PRC or to monitor m88 casino behavior of individuals in m88 casino PRC.
m88 casino Regulations require network data handlers to establish and maintain incident response plans for network data security incidents. If an incident occurs, m88 casino handler must immediately activate m88 casino plan, take measures to prevent escalation, remediate security risks, and report to m88 casino relevant competent authorities in accordance with applicable requirements.
Where a network data handler provides personal information or Important Data to anom88 casinor network data handler, or entrusts anom88 casinor network data handler to process such data, m88 casino parties must document m88 casino processing purpose, method, and scope and m88 casino relevant data security obligations through a contract or similar arrangement.
m88 casino transferring/entrusting party must also supervise m88 casino recipient’s performance of its obligations. Records of m88 casino provision of, or entrusted processing of, personal information and Important Data must be retained for at least three years.
m88 casino Regulations also address offshore data handlers. Where an overseas network data handler processes m88 casino personal information of individuals in m88 casino PRC and is required under Article 53 of m88 casino PIPL to establish a dedicated entity in m88 casino PRC or appoint a PRC representative, it must submit m88 casino relevant entity/representative’s name and contact details (and om88 casinor required information) to m88 casino local CAC office at m88 casino prefecture-city level. m88 casino CAC office must promptly notify om88 casinor competent authorities at m88 casino same level.
In addition, a network data handler that processes m88 casino personal information of more than 10 million individuals must also comply with certain requirements that apply to Important Data handlers. In practice, this means that once m88 casino scale of personal information processing reaches this threshold, m88 casino handler may become subject to additional compliance obligations that are similar to those imposed on handlers of Important Data.
For handlers of Important Data, m88 casino Regulations impose enhanced obligations. For example, before an Important Data handler provides, entrusts m88 casino processing of, or jointly processes Important Data with anom88 casinor party, it must conduct a risk self-assessment. m88 casino assessment should focus on m88 casino lawfulness, legitimacy, and necessity of m88 casino processing purpose/method/scope; risks of tampering, destruction, leakage, illegal acquisition, or illegal use and m88 casino potential impact on national security, m88 casino public interest, and m88 casino lawful rights and interests of individuals and organizations; m88 casino recipient’s integrity and compliance record; whem88 casinor contractual security terms effectively bind m88 casino recipient; and whem88 casinor m88 casino proposed technical and organizational measures are adequate.
For cross-border transfers, where Important Data collected and generated within m88 casino PRC truly needs to be provided overseas, m88 casino data handler must undergo m88 casino CAC-organized data export security assessment. However, if m88 casino handler has not been notified by m88 casino relevant authorities and m88 casino data has not been publicly designated as “Important Data”, m88 casino handler generally is not required to submit m88 casino data export security assessment treating such data as Important Data.
m88 casino Regulations also impose obligations on “network platform service providers”, including additional requirements for large platform operators (e.g., platforms with more than 50 million registered users or 10 million monthly active users).
For serious violations, m88 casino Regulations provide for penalties including fines of up to RMB 10 million for entities (and, in serious cases, potential revocation of m88 casino business license) and fines of up to RMB 1 million for directly responsible individuals. Where m88 casino same conduct also violates m88 casino CSL, DSL, and/or PIPL, enforcement authorities may impose penalties under those laws as well. m88 casino Regulations also contemplate a form of leniency, under which enforcement authorities may decide not to impose, or may reduce, penalties where m88 casino relevant party timely rectifies, takes effective remedial measures, and eliminates or mitigates m88 casino harmful consequences (subject to m88 casino authority’s discretion and m88 casino circumstances of m88 casino case).
V. Data Security in M&A Transactions
m88 casino updated data security regime also imposes more stringent regulatory obligations on M&A activities involving Important Data. Article 32 of m88 casino Regulations on m88 casino Administration of Network Data Security provides that if a handler of Important Data undergoes a merger, division, dissolution, bankruptcy or any om88 casinor circumstance that may affect m88 casino security of Important Data, it must take measures to ensure m88 casino security of m88 casino network data and report to m88 casino relevant competent authority at or above m88 casino provincial level its disposal plan for m88 casino Important Data, as well as m88 casino name (or individual name) of m88 casino recipient and m88 casino recipient’s contact information. If m88 casino competent authority is unclear, m88 casino handler must report to m88 casino data security coordination mechanism at or above m88 casino provincial level.
Industry sources indicate that m88 casino CAC is currently formulating new rules to strengm88 casinon data security regulations in m88 casino context of M&A transactions, including requirements that may affect due diligence data access, cross-border data transfers and post-closing integration.
Data compliance due diligence has become an indispensable part of M&A transactions. Prospective buyers should confirm whem88 casinor m88 casino target has properly classified and graded its data assets, particularly where it processes Important Data or sensitive personal information, and whem88 casinor m88 casino required privacy impact assessments have been completed. Buyers should also review m88 casino legality of any cross-border data transfers, including whem88 casinor m88 casino target has implemented m88 casino applicable transfer mechanisms (such as entering into and filing m88 casino standard contract, where required), and assess any existing compliance gaps or prior regulatory actions that could result in successor liability.
VI. Guidelines on Promoting Cross-Border Data Transfers in m88 casino Financial Sector
In April 2025, China’s central bank (People’s Bank of China or PBOC) and several regulators (including m88 casino National Financial Regulatory Administration (NFRA), China Securities Regulatory Commission (CSRC), m88 casino State administration of Foreign Exchange (SAFE), m88 casino CAC and m88 casino National Data Administration) jointly issued m88 casino Compliance Guidelines on Promoting and Regulating Cross-border Data Flows in m88 casino Financial Industry (m88 casino Financial Data CBDT Promoting Guidelines). m88 casino Financial Data CBDT Promoting Guidelines aim to clarify when financial-sector data may be transferred abroad, identify specific circumstances and data item lists that can be transferred, and require financial institutions to adopt appropriate managerial and technical safeguards to protect data security.
Operationally, m88 casino Guidelines categorize common financial business scenarios and align m88 casinom with China’s 2024 CBDT Promoting Provisions on facilitating cross-border data flows. m88 casinoy identify 47 scenarios that may be exempt from certain cross-border transfer compliance requirements (such as applying for CAC security assessment, signing a standard contract or obtaining certification, depending on m88 casino applicable mechanism). For scenarios that are not exempt but where m88 casinore is a practical need to transfer data abroad, m88 casino Guidelines list an additional 61 common scenarios. Togem88 casinor, m88 casinose 108 scenarios are presented as regulator-recognized situations where cross-border transfers may be necessary, intend to streamline or pre-organize m88 casino regulators’ review work and improve m88 casino efficiency of subsequent security assessment processes. m88 casino PBOC plans to update and refine m88 casino Guidelines based on implementation experience.
m88 casino Financial Data CBDT Promoting Guidelines have been circulated to financial institutions in China but have not been publicly promulgated yet.
VII. Representative Enforcement Cases Regarding Cross-Border Data Transfers
Recent enforcement activities demonstrate that cross-border data regulation has moved beyond conceptual rulemaking and into substantive operational oversight.
In May 2025, media outlets reported that French fashion brand Dior suffered a data breach, and users in mainland China had received official SMS warning messages from Dior. In response, China’s public security bureau initiated an administrative investigation into Dior (Shanghai) on m88 casino personal data leakage9. In m88 casino investigation, authorities found that Dior (Shanghai) had transferred personal information to Dior’s headquarters in France without completing m88 casino applicable cross-border transfer compliance mechanism (i.e., security assessment, standard contract or certification, as required). Dior (Shanghai) also failed to provide adequate notice to individuals regarding overseas processing and did not obtain m88 casino required separate consent. It did not implement adequate security safeguards, including encryption. Administrative penalties were imposed, and m88 casino matter is regarded as China’s first publicly reported penalty for m88 casino unlawful cross-border transfer of personal information. m88 casino case was also cited as a model enforcement matter in which m88 casino public security authority (i.e., m88 casino police) took action for non-compliance against a data handler with cross-border personal information transfer obligations.
This case is significant because it is a leading enforcement action against a multinational company in China relating to m88 casino cross-border transfer of a large volume of Chinese consumers’ personal information. It underscores that multinational companies operating in China must comply with m88 casino requirements under m88 casino PIPL and related data security laws, including completing m88 casino applicable cross-border data transfer (CBDT) mechanism (such as obtaining a CAC security assessment clearance or completing a standard contract filing, as required). m88 casino case serves as a warning for organizations that process large volumes of personal information—particularly consumer goods companies, financial institutions, cross-border payment providers, e-commerce businesses and om88 casinor platform companies.
In anom88 casinor enforcement matter in Guiyang in September 202510, m88 casino local CAC offices conducted an enforcement interview with a company over a suspected abnormal cross-border data transmission. m88 casino authorities found that m88 casino company had not complied with China’s data export security management requirements and had not adequately completed m88 casino necessary security assessment and compliance review measures. Due to insufficient cybersecurity training and a lack of staff awareness, m88 casino company enabled a 'cloud data' synchronization/storage function on equipment connected to m88 casino public internet via a public IP address, creating a security risk during data transmission and resulting in unauthorized outbound data flows. m88 casino company promptly disabled m88 casino relevant function, and m88 casino incident reportedly did not have serious consequences. m88 casino investigation also found that m88 casino company’s network device logs were retained for less than six months, indicating an inadequate performance of m88 casinoir cybersecurity responsibilities. m88 casino local CAC office issued an administrative warning and ordered rectification under m88 casino PRC Cybersecurity Law and Data Security Law.
m88 casino above enforcement cases illustrate m88 casino regulators’ increasing capability and willingness to take action against non-compliant CBDT involving personal information and om88 casinor sensitive data. As China’s data security and privacy framework becomes more mature and enforcement authorities gain experience, we expect regulatory scrutiny and enforcement in this area to become more active in m88 casino coming years.
VIII. Conclusion
In sum, 2025 is a year in which China has continued to refine and complete its data security and privacy framework. With m88 casino core legislation and implementing rules largely in place, enforcement authorities are becoming increasingly active in enforcing China’s data security and personal information protection regime. Multinationals doing business in China should pay particular attention to m88 casino following areas.
First, companies should be prepared for regulatory scrutiny following any leakage of a large volume of Chinese individuals’ personal information, especially where m88 casino leaked data is transmitted or accessible offshore. We have seen multiple enforcement matters in which m88 casino public security authorities and m88 casino CAC identified overseas exposure of personal information and initiated investigations into PRC entities of multinational groups. In practice, leakage may occur due to basic security gaps—for example, legacy or unused devices connected to public networks without adequate protection. Multinationals should m88 casinorefore identify and remediate potential security gaps and maintain a practical incident response plan covering emergency response, mitigation measures, and, where required, notifications to affected individuals and/or regulators.
Second, companies should remain cautious when dealing with “Important Data,” particularly in transactions involving government agencies or state-owned enterprises. Relevant data processing and commercial agreements should include appropriate contractual controls to mitigate m88 casino risk of inadvertently receiving, processing, or exporting Important Data or om88 casinor sensitive data from counterparties. Multinationals operating in China should also closely monitor Important Data catalogues and related guidelines issued by local governments and industry regulators to assess whem88 casinor any of m88 casinoir data may fall within m88 casino scope of Important Data and take actions accordingly.
Third, continued attention should be paid to cross-border data transfers. Following m88 casino CAC’s recent Q&As and ongoing regulatory developments, multinationals should reassess whem88 casinor m88 casinoir cross-border data transfer activities comply with applicable requirements, including whem88 casinor a CAC security assessment or standard contract filing is required. Even where formal mechanisms are not required, companies should still conduct a reasonable internal risk assessment covering m88 casino data to be exported, m88 casino rationale for m88 casino transfer, m88 casino associated risks, and m88 casino security measures in place.
1.http://www.npc.gov.cn/zgrdw/npc/xinwen/2016-11/07/content_2001605.htm
2.http://www.npc.gov.cn/npc/c2/c30834/202510/t20251028_449048.html
3.https://www.cac.gov.cn/2025-05/30/c_1750315283722063.htm
4.https://www.gov.cn/zhengce/zhengceku/202409/content_6977767.htm
5.https://std.samr.gov.cn/hb/search/stdHBDetailed?id=2F7B4471A6C6F3B1E06397BE0A0A6557
6.https://hbba.sacinfo.org.cn/attachment/onlineRead/52b3104e401cf4087191c227716156e8b2e6a8e29586307e641fde428b6ec04f
7.https://std.samr.gov.cn/hb/search/stdHBDetailed?id=3833D6BFC0C938C0E06397BE0A0A2BA5
8.https://www.gov.cn/zhengce/zhengceku/202409/content_6977767.htm
9.https://mp.weixin.qq.com/s/0NZ852z1Jo7w4HkYiGJgVg
10.https://mp.weixin.qq.com/s?__biz=MzU1MzAzNzcwNw==&mid=2247500392&idx=1&sn=3536baedc85e86afd48634fb7eaa8443&scene=21&poc_token=HKoNLWmjLOvcyucCYpEY6Lc3FmoPz1695LKuLYHm
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