It has been more than three months since thePRC Cyber Security
Law ("CSL") has taken effect on 1 June 2017. Except for
the Provisions on Examination of Network Products and Services
(Trial) ("NPS Provisions") which have come into effect on
the same day as the CSL, other regulations to supplement and
implement the CLS have not yet been enacted. So far, only some
supplementary regulations are available in draft versions for
public consultation purposes.
On 10 July 2017, the Cyberspace Administration of China
("CAC") issued a draft of the Regulations for Protection
of Critical Information Infrastructure ("CII
Regulations") for public consultation. Given the stringent
requirements for "keeping data in China" and
"national security assessments" which are initially
provided under the CSL for the Critical Information Infrastructure
("CII") and CII Operators, the draft CII Regulations
which are intended to provide clarifications on the CII and CII
Operators have generated a