In 2025, China took several notable steps to strengthen its data
privacy and cybersecurity regulatory framework, finalizing
compliance audit requirements, operationalizing the cross-border
data transfer certification regime, and amending the Cybersecurity
Law to increase penalties and expand its extraterritorial
reach.
This Advisory highlights the key developments and their
practical implications for companies operating in or handling data
from China.
Legislative & Regulatory Developments
1. Personal Information Protection Compliance Audit
Requirements
On February 12, 2025, the Cyberspace Administration of China
(CAC,
国家互联网信息办公室)
issued the Measures for the Administration of Compliance Audits on
Personal Information Protection (Audit Measures,
个人信息保护合规审计管理办法),
which took effect on May 1, 2025. The Audit Measures require data
processors (akin to controllers under the General Data Protection
Regulation (GDPR) to assess and quantify the scale of