QuestionChina

When does China cybersecurity review apply? Direct answer

Screen for review when a CII operator procures network products or services, or a network platform operator processes data, in a way that affects or may affect national security.

A network platform operator holding personal information of more than one million users must also apply before a foreign listing. That threshold is not a general safe harbour.

Author
Sorena AI
Published
Jul 5, 2026
Updated
Jul 24, 2026
Questions
2

Structured answer sets in this page tree.

Primary sources
1

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Jul 5, 2026
Updated Jul 24, 2026
Overview

China's Measures cover CII procurement and network-platform data processing that affects or may affect national security. They also require a holding of more than one million users to apply before a foreign listing.

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2 of 2 questions
Question 1

Short answer

Article 2 covers two situations when national security is or may be affected: a critical information infrastructure, or CII, operator procures network products or services; or a conducts data-processing activities. For CII procurement, Article 5 requires the operator to predict the national-security risk and apply when the product or service affects or may affect national security. For platform processing, keep a reasoned national-security analysis even though the Measures do not supply a numeric filing threshold.

Article 7 adds a mandatory trigger: a holding of more than one million users must apply before a to the Office, the CAC office that organizes the review. The threshold belongs to that trigger. It is not a safe harbour for CII procurement, other platform processing, or a review initiated by the authorities under Article 16.

The Measures say network products and services mainly include core network equipment, important communications products, high-performance computers and servers, high-capacity storage equipment, large databases and application software, network-security equipment, cloud-computing services, and other products or services with an important effect on CII, network security, or data security. This is an inclusive list, not a finding that every purchase in those categories requires review; the CII-operator and national-security tests still control.

The risk assessment is broader than a conventional technical-security test. Article 10 includes illegal control, interference, or destruction of CII; supply interruption and supplier reliability; product security, openness, transparency, and source diversity; the supplier's compliance with Chinese law; theft, disclosure, destruction, illegal use, or illegal export of , , or large amounts of ; and foreign-government influence or control associated with a listing.

If filing is required, the applicant submits an application, a national-security impact analysis, relevant procurement agreements or proposed listing documents, and other requested materials. The office has 10 working days after receiving compliant materials to decide whether a review is needed. The initial review period is generally 30 working days and may be extended by 15; a special review generally takes 90 working days and may be extended. Time spent supplying supplemental materials is excluded.

A written no-filing decision should identify the actor, transaction, product or service, supplier, system and data effects, listing facts, and national-security analysis. Reassess when those facts change. A general network-operator label or a user count below one million is not enough to close the analysis.

Citations
Cybersecurity Review Measures

Articles 2, 5, 7-16 and 21 establish the covered actors and triggers, national-security factors, filing materials, review stages and timing, authority-initiated review, and covered network products and services.

Question 2

What to keep as evidence

Keep enough information to reproduce the trigger analysis and, if applicable, the filing and authority procedure.

  • Actor record: why the entity is or is not a or for this activity, including any authority identification or sector input.
  • Transaction record: procurement, product or service, supplier and subcontractors, affected CII functions, dependencies, continuity measures, data-processing activity, or proposed foreign listing.
  • Data record: , , , user count and counting method, storage and transfers, access, recipients, and risks of theft, disclosure, destruction, illegal use, or illegal export.
  • Article 10 national-security assessment covering control or disruption, continuity, security and transparency, supply diversity and reliability, supplier legal compliance, data risks, and listing-related foreign influence or control.
  • Where filed: application, impact analysis, procurement agreement or listing documents, supplier cooperation clauses, supplemental requests and responses, preventive measures during review, written outcome, and post-review commitments.
  • Timeline record separating the 10-working-day screening decision, ordinary review, possible 15-working-day extension, special review, excluded supplemental-material time, and actual notices.
  • Reassessment triggers for CII or platform status, product or service, supplier, architecture, dependency, data type or volume, processing, export, or listing changes.
Citations
Cybersecurity Review Measures

Supports each actor, trigger, risk-factor, filing, procedure, timing, outcome, commitment, and reassessment record listed here.

Primary sources

References and citations

cac.gov.cn
Referenced sections
  • Supports each actor, trigger, risk-factor, filing, procedure, timing, outcome, commitment, and reassessment record listed here.
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