Assess whether a China data export may require CAC security assessment, a standard contract, certification, or may qualify for an exemption under current PRC rules.
Legal assessmentPRC lawAssumption-led estimate
01Enter facts
02Get estimate
03Check assumptions
04Verify or escalate
Transfer profile
The 2024 rules state that data need not be treated as important data for security-assessment filing unless identified/notified or publicly designated as such.
Use de-duplicated natural-person counts. Certain exempt transfers are excluded from the cumulative threshold count under CAC guidance.
Legal basis
Main 2024 threshold logic
Security assessment: CIIO export of PI or important data; or a non-CIIO exporting important data, ≥1,000,000 ordinary-PI individuals, or ≥10,000 sensitive-PI individuals, subject to exemptions.
Standard Contract or certification: for a non-CIIO, generally 100,000 to <1,000,000 ordinary-PI individuals, or sensitive PI below 10,000, where no exemption applies.
Possible exemption: for a non-CIIO exporting fewer than 100,000 ordinary-PI individuals and no sensitive PI, plus specified contractual, HR, emergency, overseas-origin and FTZ scenarios.
Legal authorityReview the legal-basis section and cited source before relying on the output.
Tool typeLegal assessment
ScopeNational framework first
Local checkLocal rules and authority practice may differ
National framework → matter-specific file
Context note
The tool organizes the issue. The facts determine the route.
China legal rules often begin with a national framework, while the operational answer can depend on location, dates, documents, status and authority practice. Use this result to structure the next verification step.
Check the inputs. Confirm dates, amounts, classifications and assumptions.
Read the authority. Verify the cited legal basis and effective version.
Localize the answer. Test relevant provincial, municipal or agency practice.
Working notes
Understanding this result
Use these checks before treating an automated output as a legal conclusion.
What does this tool provide?+
It provides a structured calculation, screening result or drafting aid based on the facts entered and the assumptions stated on this page.
What should be verified?+
Verify the legal authority, effective date, input data, territorial scope and any exclusions identified in the result.
Why can the operational answer differ?+
Documents, disputed facts, local implementation and authority discretion can affect the practical outcome.
When should the issue be escalated?+
Escalate material exposure, disputed facts, imminent deadlines, formal notices or any issue requiring representation or a legal opinion.
