China's Cybersecurity Law Amendment – Key Changes And Compliance Recommendations

1. Background

On October 28th, 2025, the amendment to China's Cybersecurity Law (the“CSL Amendment”) was officially promulgated during the 18th session of the Standing Committee of the 14th National People's Congress (“NPCSC”). It will take effect on January 1st, 2026.

The CSL Amendment focuses on the following three key areas: first, the alignment between the Cybersecurity Law (“CSL”) and other laws and regulations concerning cybersecurity and data compliance, such as the Personal Information Protection Law (“PIPL”) and the Data Security Law (“DSL”); second, it addresses new technologies like AI and algorithms; and, third, and most importantly, it has increased the penalties for certain well-established cybersecurity violations, and established new penalty standards for other illegal activities.