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China Privacy Law PIPL compliance checklist

China PIPL compliance checklist covering scope, processing bases, notices, sensitive information, rights, vendors, impact assessments, incidents, and exports.

For each processing activity, record the purpose, data, people, role, Article 13 basis, recipients, retention, security measures, higher-risk triggers, and any overseas transfer before launch.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Oct 15, 2026
3 sections11 primary sources
Overview

Build the checklist around each processing activity, not around one privacy policy. Record who decides the purpose and method, what personal information is used, which Article 13 basis applies, who receives it, how long it is kept, and whether sensitive information, automated decisions, entrusted processing, public disclosure, or an overseas transfer triggers extra duties.

Section 1

1. Establish scope, roles, purpose, and basis

PIPL applies to processing personal information in China. It also applies to specified processing outside China when the purpose is to offer products or services to people in China or to analyze or assess their behavior. A personal information processor is the organization or person that independently decides the processing purpose and method.

For every activity, document one Article 13 condition before processing. Consent is one condition, but the law also recognizes necessity for an individual's contract, qualifying human-resources management, legal duties, specified emergencies, public-interest news or supervision, legally public information within the permitted scope, and other conditions set by law or administrative regulation.

  • Scope owner: record whether processing occurs in China or meets an Article 3 overseas test. Preserve the facts supporting the conclusion.
  • Data owner: distinguish personal information from genuinely anonymized information, which PIPL excludes. Treat de-identified information as personal information while re-identification remains possible.
  • Business and privacy owners: state the specific purpose, direct relationship between data and purpose, minimum data set, and shortest necessary retention period unless another law or administrative regulation requires longer retention.
  • Legal and procurement owners: identify the personal information processor, any joint processor, entrusted processor, independent recipient, and overseas recipient. The contract and notice duties differ by role.
  • Overseas processor: if Article 3(2) applies, establish a dedicated institution or appoint a representative in China and file the required details with the authority responsible for personal information protection.
Section 2

2. Implement the processing controls

Give the Article 17 notice before processing in a prominent, clear, accurate, and complete form. When relying on consent, make it informed, voluntary, and explicit, provide a convenient withdrawal method, and obtain new consent if the purpose, method, or personal-information categories change.

Sensitive personal information needs a specific purpose, sufficient necessity, strict protection measures, a notice explaining necessity and impact, and, when processing relies on consent, separate consent. Information about a child under 14 is sensitive; when processing relies on consent, obtain the parent or other guardian's consent and use dedicated processing rules.

  • Product owner: verify that refusal or withdrawal does not block the product or service unless the disputed processing is necessary to provide it.
  • Rights owner: provide a convenient request channel for access, copy, correction, supplementation, deletion, explanation of processing rules, and any transfer request that meets conditions set by the Cyberspace Administration of China (CAC). Give reasons when refusing a request.
  • Security owner: maintain internal rules, data classification, appropriate encryption or de-identification, least-necessary access, staff training, and an incident plan.
  • Procurement owner: put Article 21 purpose, term, method, data categories, protection measures, rights, duties, return or deletion, supervision, and sub-entrustment controls in entrusted-processing arrangements.
  • Privacy owner: complete a personal information protection impact assessment (PIPIA) before processing sensitive information, automated decision-making, entrusted processing, transfers to another processor, public disclosure, overseas transfers, or other processing with a major effect on individual rights. Keep the assessment and processing record for at least three years.
  • Audit owner: conduct periodic compliance audits. A processor handling personal information of 10 million or more people must complete an audit at least once every two years. Other processors remain subject to PIPL's regular-audit duty, and processors handling minors' personal information must audit annually under the Regulations on the Protection of Minors in Cyberspace. From 1 September 2026, a processor in China handling personal information of fewer than 100,000 people must audit at least once every five years under the simplified-measures rules, unless a covered platform audit removes duplication or a personal information protection certification is in force; the annual minors rule still applies. For processors outside these binding intervals, CAC's April 2026 guidance points to recommended national-standard frequencies rather than adding another binding interval.
  • Governance owner: a processor handling personal information of 1 million or more people must designate a personal information protection officer, publish the officer's contact details, and report the officer's information to the competent municipal cyberspace administration within 30 working days after reaching the threshold. Report a material change within 30 working days. Measure this threshold against the current number of people whose personal information the processor handles; a calendar-year data-export count does not determine it.
Section 3

3. Complete special app, incident, and export checks

For an app, map each basic function to the official app-category rules. A provider may not refuse the app's basic function because a user declines personal information that is not necessary for that function. Other PIPL duties still apply to information that falls within the category table.

For an overseas transfer, first identify important data and critical information infrastructure operator (CIIO) status, then apply the 22 March 2024 exemptions and current-year volume bands. An exemption from the security assessment, standard contract, or certification mechanism does not erase PIPL notice, separate-consent, PIPIA, security, or overseas-recipient protection duties where those duties apply.

  • Incident lead: if personal information has been or may have been leaked, altered, or lost, take remedial measures immediately and notify the responsible authority and affected people with the Article 57 content. PIPL gives no fixed hour-based deadline.
  • Export owner: record data source, destination, recipient, important-data status, CIIO status, sensitive and non-sensitive counts from 1 January of the current year, exemption analysis, selected route, and change triggers.
  • Standard-contract owner: use the CAC form without conflicting clauses, complete the export PIPIA, allow the contract to take effect before export, and file the contract and assessment with the provincial CAC within 10 working days after effectiveness.
  • Assessment owner: where a security assessment applies, complete the risk self-assessment and prepare the application, legal instrument, and supporting materials. The current assessment result lasts three years, subject to change-trigger rules and a possible three-year extension.
Put the requirement into practice

Prepare the PIPL and data export evidence file

Assign owners, implement controls, and keep the evidence behind each PIPL checklist decision.

Research workflow
Map official sources to evidence

Research Copilot connects the official citation, decision, owner, retained evidence, and change history.

Explore next step
Talk to Sorena
Review the China route

Check the China Privacy Law scope decision and unresolved launch questions with Sorena.

Explore next step
Primary sources

References and citations

PRC Personal Information Protection Law
cac.gov.cn4 citations
Referenced sections
  • Binding source for territorial scope, processing bases, notice and consent, sensitive information, rights, processor duties, security, PIPIA, incidents, and overseas transfers.
  • Articles 3-6, 13, 19-21, 53, and 72 establish territorial scope, exclusions, processing conditions, minimization and retention, role duties, and the China representative requirement.
  • Articles 14-17, 21, 28-31, 44-57, and 59 establish notice, consent, sensitive-information, rights, security, audit, PIPIA, incident, and entrusted-processor controls.
Show 1 more
  • Articles 38-40, 55-57 establish overseas-transfer safeguards, notice and separate consent, PIPIA, and incident response.
CAC Notice on Personal Information Protection Officer Reporting
cac.gov.cn2 citations
Referenced sections
  • Current officer-reporting threshold, 30-working-day event and change deadlines, reporting authority, and online route.
  • Sets the 1-million-person officer-reporting threshold, the 30-working-day deadlines after reaching the threshold or making a material change, the municipal reporting authority, and the online reporting route.
CAC Personal Information Protection Policy Q&A, April 2026
cac.gov.cn2 citations
Referenced sections
  • Official guidance on counting people for audit thresholds, the binding annual audit rule for processors handling minors' personal information, and recommended national-standard audit frequencies outside binding intervals.
  • Clarifies that current-person counts include the stated threshold, distinguishes the binding two-year and annual audit rules from recommended national-standard frequencies, and confirms the binding annual audit rule for processors handling minors' personal information.
CAC Q&A on Simplified Measures for Small Personal Information Processors
cac.gov.cn2 citations
Referenced sections
  • Official explanation of the five-year audit cadence, certification and covered-platform exceptions, and the continuing annual rule for processors handling minors' personal information.
  • Confirms the five-year audit cadence, the certification and covered-platform exceptions, and the continuing annual rule for processors handling minors' personal information.
Measures for Personal Information Protection Compliance Audits
cac.gov.cn2 citations
Referenced sections
  • Binding audit rules effective 1 May 2025, including periodic audits and the minimum once-every-two-years cadence for processors handling personal information of 10 million or more people.
  • Articles 3-6 require periodic compliance audits and set a minimum once-every-two-years cadence for processors handling personal information of 10 million or more people; the measures took effect on 1 May 2025.
Measures for the Standard Contract for Personal Information Export
cac.gov.cn2 citations
Referenced sections
  • Binding measure for the CAC standard-contract form, export PIPIA, contract effectiveness, filing within 10 working days, and refiling triggers, as modified by the 2024 provisions.
  • Articles 5-8 establish the export PIPIA, CAC form, contract effectiveness, 10-working-day filing, and refiling triggers, subject to the controlling 2024 provisions.
Necessary Personal Information Scope for Common Types of Mobile Apps
cac.gov.cn2 citations
Referenced sections
  • Official source for the 39 common app categories, their basic functions, necessary personal information, and the no-refusal rule.
  • Defines basic functions and necessary personal information for 39 common app categories and prohibits denial of a basic function for refusal of non-necessary information.
Provisions on Promoting and Regulating Cross-border Data Flow
cac.gov.cn2 citations
Referenced sections
  • Controlling current source for export exemptions, route thresholds, three-year assessment validity, and conflicts with the older assessment and standard-contract measures.
  • Articles 2-10 establish important-data treatment, exemptions, current-year thresholds, route bands, three-year assessment validity, and continuing PIPL duties.
Measures for Security Assessment of Data Export
cac.gov.cn
Referenced sections
  • Binding measure for security-assessment preparation, filing materials, review, legal-instrument content, and reassessment triggers, as modified by the 2024 provisions.

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How should vendor contracts handle entrusted processing under PIPL?

A PIPL entrusted-processing contract must define the purpose, duration, method, personal-information categories, safeguards, and both parties' duties. See the required terms and supporting records.

Is PIPL the same as GDPR?

No. China's PIPL and the EU GDPR overlap on core privacy controls, but differ in territorial scope, legal bases, roles, sensitive data, impact assessments, and transfer routes.

What counts as sensitive personal information in China?

PIPL uses a harm-based test for sensitive personal information and lists examples such as biometrics, health, financial accounts, location traces, and all personal information of children under 14.

What is separate consent under PIPL?

Separate consent under China's PIPL is a distinct consent for a specified processing activity. See when it applies, what notice must come first, and what evidence to keep.

What records should we keep for a PIPL impact assessment?

A PIPL impact-assessment file should preserve the Article 55 trigger, processing facts, Article 56 analysis, safeguards, decision, and processing record for at least three years.

What should an app collect as necessary personal information in China?

Use China's 2021 category rules to identify necessary information for an app's basic function. Keep that function available when users decline non-necessary data.

When can a company use the China standard contract route?

Use China's standard contract route only after applying the 2024 exemptions and confirming that no CAC security assessment is required. See current thresholds, filing steps, and change triggers.

When does a China PIPL security assessment apply?

A CAC data export security assessment applies to CIIO exports, important data, and specified high-volume personal-information exports after the 2024 exemptions are applied.