When an assessment is the plausible mandatory path.
Transfers · 03
Cross-border transfers
A transfer path is a gate. Architecture slides are not a filing.
First job Name the transfer route before promising a system architecture or a date.
Do not promise a cutover before the export gate is named
Open the transfer roadmapA missed CAC or SCC step can move the date. This is a compliance clock, not a safety strip.
Start here
Key considerations
- What leaves China, and to whom?
- Which mechanism is even plausible?
- What clock sits in front of go-live?
Decision map
Keep the question bounded.
- Describe the flowCategories, volume band and overseas recipient type.
- Pick a candidate pathAssessment, SCC, certification or exemption test.
- Place it on a clockDo not promise a cutover before the gate is named.
Timeline
Sequence and clocks that change the next action.
- Before architecture lockRecipient and volume facts that change the path.
- Before go-liveFiling or contract steps that must exist.
- After go-liveOngoing records and change control.
Regulatory gates
Approvals that can hold signing or closing.
This map does not decide whether a filing is required on your facts.
When a China SCC filing is the working mechanism.
When certification is in view.
When a published test may change the path — still a test.
Quick answers
Need the short version? Start with one narrow question.
These explainers answer one question. They do not replace this topic route or a deep guide.
Curated resources
Open the asset that matches this job.
01
core guide
02China data compliance decision guide
National PIPL, transfer and cybersecurity decision desk — not a substitute for a filing pack.
deep guide
03Cross-border data transfer roadmap
Compare export mechanisms and the clocks that sit in front of go-live.
insight
HR and CRM cross-border architecture
Group HR and CRM systems as a typical transfer pattern, not a clearance.
Helpful to prepare
Facts that make the next conversation clearer.
These items are orientation aids, not a legal requirement list.
- Overseas recipients and system names at a high level
- Candidate mechanism
- Target go-live or HR/payroll date
Local context
Add the city when regulator practice changes.
CAC and industry-regulator practice can differ after the national transfer or cybersecurity question is identified.
Open city and province guidesCounsel hand-off
Need data-privacy counsel?
This hub organises PIPL, cybersecurity and export questions. It does not decide whether a transfer is lawful or whether notice is required on your facts.
Find data-privacy counsel