Research prompt
Identify the data and activity
Document the data fields, systems, purpose, scale, subjects, sensitivity, source, recipient, destination and transfer mechanism before applying a threshold or exception.
Data mapActivityTransfer
Cross-border data · maintained regulatory reference
China Important Data & FTZ Data Export Source Map.
Use this maintained source map to separate important-data identification, the national cross-border transfer framework and any locally applicable free-trade-zone negative list. Confirm the entity, activity, geography, sector, data and current official text before selecting a route.
6 topic prompts5 official routes2026-08-21 source check
01 Current instrument set
Use a maintained source set, not one isolated rule
Start with the activity, data and parties, then identify the current instrument family.
China data work can involve the PIPL, network and data-security rules, cross-border transfer mechanisms, important-data or sector requirements and operational guidance. This tracker keeps those routes visible without treating a tag as a legal conclusion.
Source set checked 21 August 2026 by China Legal Portal Editorial. Draft consultation texts are not shown as effective law.
Maintained data-governance reference
Living referencePIPL, network data and cross-border transfer source set
- Current through
- 21 August 2026
- Primary authorities
- National People’s Congress and Cyberspace Administration of China
- Use boundary
- Research orientation only; exact facts and current official texts require professional verification
02 Browse topics
Use prompts to locate the source family
Search the operational question, then verify the official text before drawing any conclusion.
Topic cards and tags are navigation aids. They do not determine whether data is personal or important, whether a transfer exists, or which mechanism applies.
Sources ↓
Research prompt
Important-data identification
Do not infer important-data status from volume alone. Check whether a competent authority has notified the operator or an applicable national, sectoral or local catalogue identifies the data.
Important dataNotificationCatalogue
Research prompt
National cross-border framework
Read the March 2024 cross-border data-flow provisions with the underlying security-assessment, standard-contract and certification instruments, including current exemptions and thresholds.
CAC provisionsAssessmentExemptions
Research prompt
FTZ negative-list eligibility
A local negative list is not automatically available because a group has an address in the area. Verify the relevant entity, processing activity, geographic scope, sector and any filing or platform conditions.
FTZEligibilityGeography
Research prompt
Current local list and version
Use the current official list and implementation material for the relevant zone. Preserve the publication date and confirm whether a later citywide, sectoral or zone-specific version has replaced it.
Local listVersionSector
Research prompt
Separate personal-information analysis
Test personal-information volume, sensitive personal information, critical-information-infrastructure status and overseas-recipient obligations separately from important-data and FTZ-list analysis.
Personal informationThresholdsRecipient
No topic prompt matches those terms.
Try a broader activity, data type, role or transfer term, then review the complete official source set.
03 Official sources
Primary text before interpretation
Keep the instrument, activity and later updates in one research trail.
01
CAC · Provisions on Facilitating and Regulating Cross-Border Data Flows
Official national provisions effective on publication. Read with the underlying transfer-route instruments and later official guidance.
↗02CAC · 2025 cross-border data policy Q&A
Official CAC explanation addressing important-data notification, FTZ negative lists and personal-information thresholds. Verify later guidance.
↗03Shanghai Lingang · FTZ data-export negative list notice
Official Lingang publication route for the Shanghai FTZ negative-list materials. Confirm the relevant list, entity and activity are within scope.
↗04Beijing · 2025 FTZ data-export negative list
Official Beijing publication of the 2025 FTZ data-export negative list. Check effective scope and current implementing requirements.
↗05Shanghai · expanded negative-list policy
Official Shanghai English policy summary concerning expanded application. Use the controlling Chinese instruments for legal analysis.
↗04 Additional checks
Data analysis is fact- and change-sensitive
Before selecting a route, preserve the facts that may change the regulatory analysis.
Processing activity
Describe collection, use, storage, access, sharing, transfer, deletion and automated decisions.
Data and people
Identify data fields, sensitivity, scale, affected individuals, important-data indicators and sector context.
Roles and systems
Map processors, entrusted parties, joint decisions, recipients, vendors, systems and access locations.
Mechanism and change
Verify exemptions or mechanisms, impact assessments, contracts, filings and operational change triggers.
05 Related routes
Continue from the source map
Move to the appropriate data decision or counsel resource.
01
Cross-Border Data Guide
Map whether a China data export exists and which current route requires testing.
→02Data & Privacy Lawyers
Find counsel for PIPL, cybersecurity, important-data and transfer questions.
→03Prepare a consultation
Prepare a bounded, non-sensitive description of the activity, data, systems and recipients.
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