Under the new rules Chinese NPOs holding more than 1 million individuals’ personal information must apply for a cybersecurity review prior to listing abroad.

By Hui Xu, Kieran Donovan, and Bianca Lee

On February 15, 2022, the Cybersecurity Review Measures (2021) (CRM 2021, unofficial English text available here) took effect. CRM 2021 was promulgated on December 28, 2021, by the Cyberspace Administration of China (CAC) and 12 other Chinese central authorities, including the Ministry of State Security,…