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Compliance guide · China

Startup compliance in China: data, cybersecurity and AI rules.

PIPL, the Data Security Law, the Cybersecurity Law, cross-border data rules, generative AI measures, algorithm filing and AI-content labelling.

China has one of the most developed digital regulatory systems in the world, built on three laws (the Cybersecurity Law, Data Security Law and PIPL) and a growing body of CAC regulations on algorithms, deep synthesis, generative AI and labelling. The rules reach offshore companies that process data of people in China.

For most foreign startups, the first question is scope: are you serving users in China, processing their data, or launching AI services there? If so, plan for localisation, a transfer mechanism, a local representative and, for AI, filing and labelling.

Data laws
PIPL (2021), Data Security Law (2021), Cybersecurity Law
Regulator
Cyberspace Administration of China (CAC)
Transfers
Security assessment, standard contract or certification
Generative AI
Interim Measures (Aug 2023), algorithm filing
Labelling
AI content labelling measures from 1 Sep 2025
Penalties
Up to RMB 50 million or 5% of prior-year turnover (PIPL)

Who needs to comply

Companies processing personal information of people in China

PIPL applies within China and extraterritorially to processing for providing products or services to, or analysing, people in China.

Public-facing generative AI services in China

The Interim Measures, algorithm filing and security assessment rules apply.

Content platforms

Deep synthesis and labelling rules require labels and review duties for AI content.

Companies exporting data from China

Cross-border transfer mechanisms apply, with thresholds eased in 2024.

The laws, in detail

01

Personal Information Protection Law (PIPL)

Personal information processing, consent, sensitive data, rights, transfers and offshore processors.

When it applies

Processing in China, or abroad for providing products/services to or analysing people in China.

What you must do

  • Legal basis, often consent; separate consent for sensitive data and transfers
  • Personal information protection impact assessments
  • Local representative or entity for offshore processors
  • Data subject rights and breach remediation

Regulator

CAC and sector regulators

Penalties

Up to RMB 50 million or 5% of prior-year turnover, plus business suspension.

02

Cross-border data transfer rules

Mechanisms for exporting personal information and important data.

When it applies

Transferring personal information or important data out of China.

What you must do

  • Security assessment, standard contract filing or certification depending on volume and sensitivity
  • Exemptions for some contract performance and HR transfers since March 2024

Regulator

CAC

Penalties

Under PIPL and the Data Security Law.

03

Data Security Law & Cybersecurity Law

Data classification, important data, network security and multi-level protection.

When it applies

Data processing activities and network operators in China.

What you must do

  • Classify data and protect important data
  • Multi-level protection scheme for networks
  • Incident response and reporting

Regulator

CAC; Ministry of Public Security

Penalties

Fines and suspension.

04

Generative AI, algorithm and labelling rules

Interim Measures for Generative AI Services, algorithm recommendation and deep synthesis rules, and AI content labelling measures.

When it applies

Providing generative AI or algorithmic services to the public in China; distributing AI content.

What you must do

  • Algorithm filing and security assessment
  • Lawful training data and content governance
  • Explicit and implicit (metadata) labels on AI content
  • User complaint mechanisms

Regulator

CAC

Penalties

Orders, suspension and fines under the underlying laws.

05

Regulations on the Protection of Minors Online (2024)

Online protection of minors, including personal information of children.

When it applies

Online services used by minors in China.

What you must do

  • Minor modes and time limits where required
  • Separate rules for personal information of under-14s
  • Compliance audits of minors’ data processing

Regulator

CAC and sector regulators

Penalties

Orders, fines and suspension.

Compliance checklist

01 · Decide scope

  • Do you have users or data subjects in China?
  • Will you launch AI services to the public in China?
  • Do you export data from China?

02 · If in scope

  • Local representative or entity
  • PIPL consent and separate consents
  • Transfer mechanism by volume and sensitivity
  • Data localisation design

03 · For AI services

  • Algorithm filing and security assessment
  • Training data governance
  • Labelling and metadata for AI content
  • Local partner strategy

Key dates

  1. Jun 2017Cybersecurity Law
  2. Sep 2021Data Security Law
  3. 1 Nov 2021PIPL
  4. 15 Aug 2023Generative AI Interim Measures
  5. Mar 2024Cross-border data flow easing rules
  6. 1 Sep 2025AI content labelling measures

Common mistakes

  • Assuming offshore hosting avoids PIPL
  • Launching GenAI features without filing
  • Using one global consent for China

FAQs

Can we serve Chinese users from abroad?

PIPL may still apply, requiring a local representative and compliant consent and transfers. AI services face additional rules.

Do we need a local partner for AI?

Often, in practice, because of filing, security assessment and content governance requirements. Take local advice.

In the law library

Sources

Reviewed 12 October 2026. General information, simplified for planning; not legal advice. Check current law before relying on any requirement, and get advice for your facts. For markets outside India, advice is coordinated with locally qualified counsel.

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