PrivacyChina

China Privacy Law data export security assessment workflow

Workflow for screening data export security assessment triggers, materials, owners, and evidence records.

Use the CAC security-assessment route when a 2024 trigger applies and no exemption displaces it. Classify the data and exporter first, then count exports from 1 January of the current year.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Jul 24, 2026
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4

Cited legal and guidance references.

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

A data exporter must apply through its provincial cyberspace administration for a CAC security assessment when a 2024 trigger applies and no exemption controls. The triggers cover a critical information infrastructure operator exporting personal information or important data, and another data processor exporting important data, personal information of at least 1 million individuals excluding sensitive personal information, or sensitive personal information of at least 10,000 individuals, counted from 1 January of the current year. Do not use the older 2022 thresholds where they conflict with the 2024 provisions.

Section 1

1. Screen the route before preparing the filing

Start with the actual outbound data flow, including remote access from outside China. Identify the exporter, the overseas recipient, the data collected or generated in China, the purpose, the transfer method, and onward transfers. Count individuals cumulatively across the exporter from 1 January, rather than per product, recipient, or contract.

For important data, the 2024 provisions say a processor need not file on that basis unless a relevant department or region has identified or publicly designated the data as important. This does not remove the duty to identify and report important data under applicable rules.

  • Apply for a security assessment if the exporter is a critical information infrastructure operator and exports personal information or important data.
  • For another data processor, apply if it exports important data, personal information of at least 1 million individuals excluding sensitive personal information, or sensitive personal information of at least 10,000 individuals since 1 January of the current year.
  • Before filing, test the 2024 exemptions for data containing neither personal information nor important data, qualifying re-export of personal information collected abroad, a transfer necessary for an individual's contract, qualifying cross-border human-resources management, an emergency protecting life, health, or property, and an applicable free-trade-zone negative-list arrangement.
  • If no assessment trigger applies, document whether the standard contract, personal information protection certification, or an exemption is the correct route. Do not split volumes among entities, systems, or contracts to avoid an assessment that is otherwise required.
Sources for this answer
Measures for Security Assessment of Data Export
Articles 5-14 set the self-assessment, filing materials, provincial completeness review, CAC acceptance and assessment periods, overseas-recipient contract content, review request, and change triggers.
Provisions on Promoting and Regulating Cross-border Data Flow
Articles 2-9 supply the current important-data rule, exemptions, exporter and volume triggers, precedence over inconsistent older rules, and three-year result period.
PRC Data Security Law
Supports the underlying duties to classify data, protect important data, assess risk, maintain security controls, and respond to incidents.
Section 2

2. Complete the self-assessment and filing package

Complete the export risk self-assessment before filing. It should address the legality, legitimacy, and necessity of the transfer; scale and sensitivity; risks to national security, public interests, individuals, and organizations; the overseas recipient's obligations and capability; incident and rights-handling arrangements; and whether the legal instrument allocates the required security responsibilities.

  • File through the provincial cyberspace administration using the CAC Data Export Declaration System or another route accepted by the responsible provincial authority. Submit the application, export risk self-assessment report, proposed legal instrument with the overseas recipient, and any other material required by the current filing guide. The second-edition guide explains the filing process and package; the binding measures control the legal duty.
  • The legal instrument should cover transfer purpose, method, and scope; overseas use and processing; storage location and period; deletion or other handling at expiry or termination; onward-transfer restrictions; material changes in control or legal environment; security measures; incident response; remedies; liability; dispute resolution; and channels for individuals to exercise rights.
  • The provincial authority has five working days to check completeness. After receiving the package, the CAC has seven working days to decide acceptance. The CAC's stated assessment period is 45 working days after written acceptance, but complex cases or requests to supplement or correct materials can extend it.
  • If the result is disputed, the exporter may request re-assessment from the CAC within 15 working days after receiving it. The re-assessment result is final under the 2022 measures.
Sources for this answer
Measures for Security Assessment of Data Export
Articles 5-13 specify the self-assessment topics, application contents, five-, seven-, and 45-working-day stages, contract subjects, supplementation process, and 15-working-day re-assessment window.
CAC Data Export Security Assessment Filing Guide, Second Edition
Official procedural guidance for the current declaration system, submission process, and optimized security-assessment filing materials.
Section 3

3. Control the approved transfer and reapply when facts change

A successful assessment result is valid for three years from the result date under the 2024 provisions. The transfer still has to remain within the assessed facts and legal instrument. Keep the route analysis, counts, data map, self-assessment, submitted package, correspondence, result, contract, transfer controls, incident records, and individual-rights records together.

  • Reassess whether a new filing is required when purpose, method, scope, data category, sensitivity, overseas use, storage period, recipient control, the legal instrument, or the recipient jurisdiction's law or security environment changes in a way that affects export security.
  • If the result will expire, the export must continue, and no reapplication trigger has occurred, apply through the provincial authority for an extension at least 60 working days before expiry. CAC approval may extend the result for another three years.
  • Maintain a live cumulative count of exported individuals, separated into sensitive and other personal information, and assign an owner to monitor threshold crossings.
  • A route exemption removes the specified filing, standard-contract, or certification step; it does not by itself remove PIPL notice, separate-consent, impact-assessment, security, or incident duties that otherwise apply.
Sources for this answer
Provisions on Promoting and Regulating Cross-border Data Flow
Articles 9-13 establish the three-year result period, extension route, continuing personal-information and security duties, supervision, and precedence over inconsistent older measures.
Measures for Security Assessment of Data Export
Article 14 identifies changes that require a new assessment; its former two-year period and renewal rule are displaced by the 2024 provisions.
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Primary sources

References and citations

PRC Data Security Law
cac.gov.cn
Referenced sections
  • Supports the underlying duties to classify data, protect important data, assess risk, maintain security controls, and respond to incidents.
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