ARTICLE · 05 NOVEMBER 2025
Cybersecurity Law Revision Progresses With Expected Hike In Penalties
In September, China concluded an administrative penalty case related to personal information protection, once again underscoring the importance of compliance with cross-border data transfer requirements and personal information protection impact assessments.
Takeaways
- In September, China concluded an administrative penalty case
related to personal information protection, once again underscoring
the importance of compliance with cross-border data transfer
requirements and personal information protection impact
assessments. The public security cyber department found that a
company providing foundational datasets for AI training failed to
conduct personal information protection impact assessment before
processing sensitive biometric data such as facial information. The
company was penalized and ordered to rectify the issue.
- The National People's Congress launched the third round of
public consultation on the Draft Amendment to the Cybersecurity
Law. The draft largely aligns with the version released by the
Cyberspace Administration of China in March and proposes a
significant increase in the maximum penalties for violations of
cybersecurity obligations. If adopted, the maximum fine for
enterprises could reach RMB 10
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