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ARTICLE · 15 FEBRUARY 2026

Processing Personal Information of Minors in China? New Audit Requirement

We expect the Announcement to have the most immediate and material impact on the "key coverage" industries.

ChinaPrivacy

On 29 December 2025, the Cyberspace Administration of China (CAC) issued the Announcement on Submitting the Compliance Audit Status of Minor Personal Information Protection (the "Announcement"). It introduces a recurring, annual filing obligation: any personal information (PI) handler that processes personal information of minors is expected to conduct a compliance audit of its processing activities of minor's personal information and submit the audit status to the competent CAC by 31 January of the following year.

The filing package should comprise of:

  • Undertaking Letter;
  • Minor Personal Information Protection Compliance Audit Report (if available); and
  • Annual Compliance Audit Status Form.

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