China Digital Economy - Monthly Policy Updates (July 2025)
The China-Britain Business Council will collaborate with LexisNexis as part of the working group programme to provide you the latest updates on the digital economy including case studies, insights, and analysis.
CAC Announces Record-Filing Details for the Application of Facial Recognition Technology
【2025-06-01】
On June 1, 2025, the Security Management Measures for the Application of Facial Recognition Technology officially came into effect. Article 15 of the Measures sets out record-filing requirements for the application of facial recognition technology. According to the announcement issued by the Cyberspace Administration of China (CAC):
(1) Personal information processors that applied facial recognition technology and stored facial information of 100,000 or more individuals prior to June 1, 2025 must complete the record-filing procedure with the local provincial-level cyberspace authority by July 14, 2025; (2) Starting from June 1, 2025, personal information processors that reach the threshold of storing facial information of 100,000 or more individuals must complete the record-filing procedure with the local provincial-level cyberspace authority within 30 working days of reaching the threshold. The record-filing process will be done online via the designated system (https://grxxbh.cacdtsc.cn) and requires the submission of materials including the Basic Information Form of Personal Information Processor, the Record-filing Form for the Application of Facial Recognition Technology, and a Personal Information Protection Impact Assessment Report. In the event of any substantial changes to the filed information, the change procedure must be completed within 30 working days of the change. If the application of facial recognition technology is terminated, the record-filing must be cancelled within 30 working days of the termination.
CAC Releases Guide to Applications for Security Assessment of Outbound Data Transfers (Third Edition)
【2025-06-27】
On June 27, 2025, the Cyberspace Administration of China (CAC) released the Guide to Applications for Security Assessment of Outbound Data Transfers (Third Edition). This edition emphasizes the rules for extending the validity period of assessment results and streamlines both the application materials and procedures. According to the Provisions on Facilitating and Regulating Cross-border Data Flow and the new Guide, security assessment results for outbound data transfers remain valid for three years. If an extension is needed and none of the circumstances requiring re-application apply, the data processor may apply for an additional three-year extension within 60 working days prior to the expiration of the original validity period.
Key conditions for applying for an extension include: a. No changes in the purpose, scope, or recipients of outbound data transfers; b. The volume of outbound data transfers in the next three years will not exceed 120% of the originally approved volume; c. Legal documentation with overseas recipients remains compliant; and d. The processor has maintained compliance over the past three years, with no major data security incidents. In terms of application materials, if the Unified Social Credit Code and other identification details remain unchanged, they do not need to be resubmitted, while a new form, titled Application for Validity Period Extension for Assessment Result, must be submitted and must include scenario-specific compliance information. The updated Guide also includes optimized system operation instructions, consolidates the previously separate Letter of Undertaking into other templates, and clarifies that for the “outbound data transfer chain,” only key data is required—such as the data processor, the network domain/address of the overseas recipient, and the method of transfer—thereby reducing the compliance burden on enterprises.
China Automotive Cross-Border Data Working Group Officially Formed
【2025-06-04】
On June 4, the Inauguration and Symposium of the China Automotive Cross-Border Data Working Group was successfully held under the auspices of the Shanghai Municipal Bureau of Data and the Lin-gang Special Area Administration. The event was co-hosted by CATARC-Lin-gang Data Technology (Shanghai) Co., Ltd. and Shanghai Lin-gang Economic Development (Group) Co., Ltd., and brought together nearly 100 industry leaders.
Mr. Lu Sen, Director of the Data Department of the Lin-gang Special Area Administration, noted that Lin-gang has taken the lead in establishing a categorized and tiered management mechanism for cross-border data flows. It has pioneered a governance model that combines a negative list with operational guidelines. Additionally, it has launched the country's first grassroots-level cross-border data service center established by a cyberspace authority, and released service packages to support the development of an international data economy, aiming to create an end-to-end “green channel” for corporate cross-border data transfers. Mr. Lu expressed his hope that the newly established working group would contribute to policy and institutional innovation in cross-border automotive data flows in Lin-gang and help deliver more comprehensive and professional one-stop services for automakers.
At the event, Mr. Guo Runqing, General Manager of CATARC-Lin-gang Data Technology, officially announced the establishment of the China Automotive Cross-Border Data Working Group. The group also formally appointed its first cohort of experts, comprising leading figures from the complete vehicle, auto parts, and intelligent connected vehicle sectors, as well as top scholars from universities and research institutes. Their participation is expected to provide strong intellectual support for the working group’s future development.