
The Measures outline requirements and procedures for self-initiated and regulator-mandated compliance audits from May 1, 2025.
By Hui Xu and Bianca H. Lee
The Cyberspace Administration of China’s (CAC’s) official release of the Measures for Personal Information Protection Compliance Audits (the Measures) marks the CAC’s commitment to implementing the compliance audit system under the PIPL, which has been in effect since November 1, 2021. There was no formal guidance on or implementation of this requirement prior to the publication of the Measures, aside from a draft version of the Measures. The Measures took effect on May 1, 2025 (an unofficial English translation can be found here).
Compliance audits are mandatory for personal information processors (PI Processors) subject to PIPL, as stipulated in Articles 54 and 64 of the PIPL and Article 27 of the Regulations on Network Data Security Management (Network Data Regulations).