Draft Provision On The Collection And Use Of Personal Information On Internet Applications Enhancements And Challenges

The Draft Provision on the Collection and Use of Personal Information on Internet Applications (the “Draft Provision”) was released by the Cyberspace Administration of China for public consultation in January, 2026, with a consultation period of one month. The Draft Provision was issued under the background of widely use of internet applications in all business sectors and an increasingly complicated business ecosystem comprised of, in addition to mobile and internet applications (“Apps”), software development kits (SDKs), distribution platforms, and intelligent terminals installed with Apps. It is also to consolidate maturing but fragmented regulatory instruments governing personal information protection in Apps, including those ministerial rules, normative notices, enforcement guidelines, and national and organizational standards targeting App compliance. The Draft Provision seeks to respond to these challenges by consolidating existing rules, elevating