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China Privacy Law PIPL cross-border transfer route selector

Step-by-step selector for China's data-export exemptions, CAC security assessment, , and .

Use the 22 March 2024 rules: test exemptions first, mandatory security assessment second, and the or certification bands third.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Oct 15, 2026
3 sections5 primary sources
Overview

Use this order for each data flow: confirm an overseas provision, classify personal information and , determine critical information infrastructure operator (CIIO) status, test the 2024 exemptions, count affected individuals from 1 January of the current year, and select the route. Do not apply the older 2022 security-assessment or 2023 standard-contract volume tests where they conflict with the 2024 provisions.

Section 1

Steps 1-3: flow, data, and exemptions

Step 1: document what leaves China, how the overseas recipient obtains it, and whether the flow contains personal information or . If it contains neither, the 2024 provisions exempt it from security assessment, the , and certification.

Step 2: determine important-data status. If no department or region has notified the processor or publicly classified the data as , Article 2 says the processor need not declare a security assessment on the basis that it is important data. Record the classification evidence rather than guessing from commercial sensitivity.

  • Step 3A: exempt personal information collected overseas, sent into China for processing, and then provided overseas if no personal information collected in China and no is introduced during China processing.
  • Step 3B: exempt a transfer necessary for the individual's contract, qualifying cross-border HR management, or an emergency protecting life, health, or property. The transfer must be necessary for the stated condition.
  • Step 3C: for a non-CIIO, exempt fewer than 100,000 individuals' personal information provided overseas since 1 January of the current year, excluding sensitive personal information. is not covered.
  • Step 3D: for a processor in a pilot free-trade zone, check the approved negative list. Data outside that list may be exempt from the three mechanisms.
Section 2

Steps 4-5: mandatory assessment or intermediate route

Step 4: route any CIIO provision of personal information or to the Cyberspace Administration of China (CAC) security assessment. For a non-CIIO, security assessment is mandatory for important data, personal information of at least 1 million individuals excluding sensitive information, or sensitive personal information of at least 10,000 individuals. The personal-information counts run cumulatively from 1 January of the current year.

Step 5: if no exemption or security-assessment trigger applies, a non-CIIO must use either the CAC or when it has provided personal information of at least 100,000 but fewer than 1 million individuals excluding sensitive information, or sensitive personal information of fewer than 10,000 individuals. The general sub-100,000 exemption excludes sensitive personal information, so a smaller sensitive-information export still reaches Step 5 unless another exemption applies.

  • Security-assessment output: risk self-assessment, application, proposed legal instrument, other requested materials, and a tracked CAC result. The current result lasts three years, subject to change triggers.
  • Standard-contract output: personal information protection impact assessment (PIPIA) for the export, the CAC form plus any non-conflicting additional terms, effective contract before export, and filing with the provincial CAC within 10 working days after effectiveness.
  • Certification output: application to a qualified certification body, the supporting assessment and protection evidence, and the resulting certificate and status record. The Personal Information Export Certification Measures took effect on 1 January 2026; a certificate is valid for three years, and continued use requires a new application six months before expiry.
  • Anti-avoidance check: do not split quantities to route data through the when security assessment is legally required.
Section 3

Step 6: complete PIPL duties and preserve the decision

Mechanism selection is only one part of compliance. For personal information provided overseas, take necessary measures to ensure the overseas recipient meets PIPL's protection standard, give the Article 39 notice, obtain separate consent where required, and complete the Article 55 PIPIA. The 2024 exemptions remove the three route mechanisms, not every underlying PIPL duty.

Recalculate the route when the facts change and at least when the annual count restarts on 1 January. The important triggers include data categories, sensitive status, important-data status, CIIO status, counts, recipient, purpose, method, overseas retention, onward transfer, destination law, or ownership and control. A route conclusion for one flow, recipient, and year does not automatically govern another.

  • Record source, destination, recipient, access method, purpose, data categories, sensitive status, onward transfers, and retention.
  • Record CIIO status, important-data notification or public classification, and the method used to count individuals from 1 January.
  • Keep the exemption or route analysis, PIPIA, Article 39 analysis, recipient safeguards, contract, certification or assessment evidence, filing receipt, owner, approval, and change triggers.
  • Boundary: a final route cannot be chosen from volume alone. CIIO status, , sensitive information, the exact exemption facts, and applicable free-trade-zone rules can change the result.
Put the requirement into practice

Prepare the PIPL and data export evidence file

Assign an export owner and keep the flow facts, classifications, counts, route decision, filings, approvals, and change triggers together.

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Primary sources

References and citations

Provisions on Promoting and Regulating Cross-border Data Flow
cac.gov.cn4 citations
Referenced sections
  • Controlling current source for important-data treatment, exemptions, route thresholds, assessment validity, continuing duties, and conflicts with older measures.
  • Articles 2-6 establish important-data treatment and the non-personal-data, overseas-origin, contract, HR, emergency, sub-100,000, and free-trade-zone exemption tests.
  • Articles 7-9 establish current mandatory-assessment and intermediate route bands, current-year counting, three-year validity, and assessment extension.
Show 1 more
  • Articles 10, 11, and 13 preserve applicable PIPL and security duties and make the 2024 provisions controlling over inconsistent older measures.
Measures for Security Assessment of Data Export
cac.gov.cn2 citations
Referenced sections
  • Binding measure for security-assessment preparation, materials, review, legal-instrument content, and reapplication, as modified by the 2024 provisions.
  • Articles 5-14 specify the self-assessment, application materials, legal-instrument content, review process, and reapplication triggers, subject to the 2024 provisions.
Measures for the Standard Contract for Personal Information Export
cac.gov.cn2 citations
Referenced sections
  • Binding measure for the CAC contract form, export PIPIA, effectiveness, filing, anti-splitting rule, and refiling, as modified by the 2024 provisions.
  • Articles 4-8 prohibit quantity splitting and specify the export PIPIA, CAC form, effectiveness, 10-working-day filing, and refiling, subject to the 2024 provisions.
Personal Information Export Certification Measures
cac.gov.cn2 citations
Referenced sections
  • Current binding source for the certification route, eligible volume band, application, certificate validity, renewal timing, status changes, and continuing export duties; effective 1 January 2026.
  • Articles 3 and 5-10 define the certification route, current eligible band, application and certificate process, three-year validity, six-month renewal lead time, and certificate suspension or revocation; effective 1 January 2026.
PRC Personal Information Protection Law
cac.gov.cn2 citations
Referenced sections
  • Binding source for route mechanisms, overseas-recipient protection, notice, separate consent where required, localization, security assessment, and PIPIA.
  • Articles 38-40, 55, and 56 establish route conditions, overseas-recipient protection, notice, separate consent where required, PIPIA, and three-year record retention.

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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.

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