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China Inbound Legal Guides · Data export workflow

China SCC Filing: Timeline and Cost Themes

A China standard contract is a filing route, not a licence and not a substitute for selecting the correct outbound-transfer mechanism. Confirm the path, complete the impact assessment, execute the official template and prepare for supplements.

Workflow guide

Operational orientation · Qualified PRC counsel required for fact-specific decisions

Workflow principle

Confirm the transfer path before preparing the filing pack.

First establish why a security assessment or another mechanism does not apply. Then complete the personal-information protection impact assessment, use the official China standard contract, file with the competent cyberspace administration and maintain change control after filing.

Filing workflow

Run the filing in four controlled stages.

Timing depends on data mapping, contracting, the competent authority and supplement requests.

Time on site

Check current CAC rules, role and volume tests, critical-information-infrastructure status and important-data exposure. Record why a security assessment is not the selected path.

Path-selection line

Do not upload a GDPR annex and call it a China standard contract. European contractual clauses may coexist with the China documentation but do not replace the official China filing route.

Filing pack

Keep four records aligned.

A defensible filing connects the legal path to the actual systems and parties.

01

Path memorandum

Why the transfer is on the standard-contract route under current rules.

Route track
02

Data map

Systems, data, people, recipients, purposes and access paths.

Fact track
03

Impact assessment and contract

Risk analysis, safeguards and the official executed template.

Document track
04

Change control

Ownership for supplements and future system or vendor changes.

Operations track
Before filing

Check the pack before submission.

Selections stay in this browser and are not submitted.

Frequently asked questions

Two recurring filing questions.

These answers are general orientation.

How much does SCC filing cost?

There is no useful public sticker price. Budget internal mapping, legal drafting, contract alignment and possible supplements rather than treating it as a marketplace filing fee.

Can GDPR standard contractual clauses be used instead?

No. They may sit in the same compliance programme, but they do not satisfy the China standard-contract filing requirements.

Source station

Use current CAC materials and the maintained China data guides.

Related routes

Open the page that owns the next decision.

Use the broader path finder before filing and the specialist page for the underlying data set.

Legal escalation

Escalate when the path or filing facts are uncertain.

Current thresholds, important-data questions and hidden transfers require fact-specific analysis.

Important data may be presentThe transfer may belong on a different regulatory path.

Systems do not match the draftGlobal access, vendors or onward transfers are missing from the map.

A material change occursA new recipient, purpose, data set or system changes the filed position.

Educational information only — not legal advice. Laws, procedures and regulatory practice can change; no lawyer-client relationship is created through use of this page.