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 20, 2021, the Standing Committee of the National People’s Congress adopted the Personal Information Protection Law of the People’s Republic of China (PIPL), the first legislation dedicated to protecting personal information in China. PIPL will take effect on November 1, 2021. PIPL previously
On July 30, 2021, the State Council of the People’s Republic of China (PRC) published the Security Protection Regulations on the Critical Information Infrastructure (the Regulations), which was adopted by the State Council on April 27, 2021. The Regulations took effect on September 1, 2021, along with the recently passed
On July 3, 2020, the Standing Committee of the National People’s Congress of the People’s Republic of China (PRC) issued the draft Data Security Law (DSL) for public comment. Once finalized, the DSL, together with the PRC Network Security Law and the proposed PRC Personal Information Protection Law, will form an increasingly comprehensive legal framework for information and data security.