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ARTICLE · 05 AUGUST 2025

China's New DPO Registration Requirement: What You Need To Know

K&L Gates
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On 18 July 2025, China's Cyberspace Administration (CAC) officially launched its online portal (Portal) for registration of China Data Protection Officers (China DPO)

ChinaPrivacy
Amigo L. Xie
Amigo L. Xie
Dan Wu
Dan Wu
Sarah Kwong
Sarah Kwong

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 the Personal Information Protection Law (PIPL).

Who Must Appoint a China DPO?

Data controllers processing over one million individuals' personal information should appoint a China DPO. In addition, some recommended national standards set additional scenarios as best practice.

Who Must Register their China DPO?

Data controllers processing over one million individuals' personal information in China must register their China DPOs. While Article 53 of PIPL and the template registration forms provided by CAC suggest that offshore PIPL data controllers may also be subject to this requirement, clarification is needed on portal documentation requirement.

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