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When can a company use the China standard contract route? Direct answer

Under the 2024 CAC provisions, a non-CIIO must use the standard contract or personal-information protection certification for specified mid-range exports, unless an exemption applies. Important data and higher-volume exports require a security assessment instead.

Count exports from January 1 of the current year, separate sensitive from other personal information, and document the exemption and route analysis before transfer.

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

The standard-contract measures took effect on June 1, 2023, and the CAC's March 22, 2024 provisions now control where the rules conflict. A non-CIIO can use the for a personal-information export that is not exempt and does not require a CAC security assessment. The standard contract or certification is required when, from January 1 of the current year, the exporter provides personal information of at least 100,000 but fewer than 1 million individuals excluding sensitive personal information, or any sensitive personal information involving fewer than 10,000 individuals.

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Question 1

Apply the routing tests in order

First decide whether the activity provides data outside China and whether that data contains personal information or important data. Then apply the 2024 exemptions. Next determine whether the exporter is a critical information infrastructure operator (CIIO), whether important data is involved, and how many individuals' non-sensitive and sensitive personal information has been exported since January 1.

A CIIO exporting personal information or important data must use the security-assessment route. A non-CIIO must also use that route for important data, personal information of at least 1 million individuals excluding sensitive personal information, or sensitive personal information of at least 10,000 individuals. For a non-CIIO, Article 8 places exports from 100,000 to under 1 million individuals excluding sensitive personal information, and exports involving any sensitive personal information below 10,000 individuals, in the standard-contract-or-certification band unless an exemption controls.

  • No personal information or important data: specified international-trade, cross-border transport, academic-cooperation, transnational-production, and marketing data can be exempt from all three CAC transfer mechanisms.
  • Overseas-origin information: personal information collected outside China, processed in China, and sent out again is exempt if no personal information or important data collected or generated in China is introduced during processing.
  • Necessary individual contract, qualifying cross-border HR management, or emergency: these exports can be exempt when every stated condition is met and no important data is included.
  • Low-volume non-sensitive export: a non-CIIO exporting personal information of fewer than 100,000 individuals since January 1 is exempt only for the count excluding sensitive personal information. Sensitive information requires its own route analysis.
  • Free-trade-zone rule: a qualifying exporter in a pilot free-trade zone may rely on the approved negative-list framework for data outside that list.
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Question 2

Complete the contract, assessment, and filing

Complete the export PIPIA before the transfer. It should examine the legality, legitimacy, and necessity of both parties' processing; the exported information's scale, scope, categories, and sensitivity; risks to individuals; the overseas recipient's commitments, measures, and capability; the availability of rights channels; and the effect of the recipient country's or region's law on performance.

Use the CAC contract in the form attached to the measures. Additional terms are allowed only if they do not conflict with it. The contract must take effect before the export begins. File the effective contract and PIPIA report with the provincial CAC within 10 working days after effectiveness; filing is not described as an approval of the export.

  • Route record: exporter and recipient, CIIO status, important-data conclusion, count period, non-sensitive count, sensitive count, exemption analysis, and selected route.
  • PIPIA: source data, purposes, methods, locations, retention, onward transfers, rights channels, recipient controls, local-law analysis, risks, and safeguards.
  • Contract file: prescribed contract, any non-conflicting additions, signatures, effective date, scope matching the PIPIA, and the date export began.
  • Filing evidence: contract, PIPIA report, submission date, provincial CAC destination, receipt or other available evidence, and confirmation that the filed materials were accurate.
  • Reassessment: repeat the PIPIA, supplement or replace the contract, and complete the corresponding filing when specified purposes, scope, categories, sensitivity, methods, storage location, overseas use, retention, foreign law, or another rights-affecting fact changes.
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