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).
On August 22, 2019, the Cyberspace Administration of China (CAC) released a new data privacy regulation related to children, the Provisions on Cyber Protection of Personal Information of Children (儿童个人信息网络保护规定)(PCPPIC). The regulation will come into effect on October 1, 2019, and will apply within the People’s Republic of China (PRC).The PCPPIC’s stated purpose is “protecting the security of children’s personal information and promoting the healthy growth of children in the PRC.” In 29 Articles, the PCPPIC sets forth high-level requirements for the collection, storage, use, transfer, and disclosure of the personal information of children within PRC territory.