PrivacyChina

China Privacy Law personal information standard contract filing workflow

Workflow for the PIPL standard contract route, assessment, filing package, and cited evidence.

For a non-CIIO within the 2024 volume band, use the CAC standard contract or certification unless an exemption or security-assessment trigger controls. Complete the export impact assessment before the transfer.

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Sorena AI
Published
Jul 5, 2026
Updated
Jul 24, 2026
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Cited legal and guidance references.

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

A non-critical-information-infrastructure operator must use the CAC standard contract or personal information protection certification when, from 1 January of the current year, it exports personal information of at least 100,000 but fewer than 1 million individuals excluding sensitive personal information, or exports sensitive personal information of fewer than 10,000 individuals, unless a 2024 exemption or a security-assessment trigger applies. The standard contract route requires an export impact assessment, the prescribed CAC contract text, an effective contract before export, and provincial filing within 10 working days after the contract takes effect.

Section 1

1. Confirm that the standard contract route applies

Map the outbound flow and count exported individuals cumulatively from 1 January across the exporter. Separate sensitive personal information from other personal information. The 2024 provisions govern the current thresholds and prevail where the 2023 measures are inconsistent.

Do not start with the contract form. First rule out important data, critical information infrastructure operator status, the security-assessment thresholds, and the 2024 exemptions. An exporter within the standard-contract band may choose certification instead.

  • Security assessment controls if a non-CIIO 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.
  • The standard contract or certification band is at least 100,000 but fewer than 1 million individuals for non-sensitive personal information, or fewer than 10,000 individuals for sensitive personal information.
  • The route exemptions include specified no-PI-or-important-data flows, qualifying re-export of information collected abroad, transfers necessary for an individual's contract, qualifying cross-border human-resources management, emergencies protecting life, health, or property, and applicable free-trade-zone negative-list arrangements.
  • The under-100,000 exemption for a non-CIIO expressly excludes sensitive personal information and important data. Do not apply it to sensitive personal information merely because the count is low.
Sources for this answer
Provisions on Promoting and Regulating Cross-border Data Flow
Articles 2-8 provide the current important-data rule, exemptions, security-assessment triggers, and standard-contract or certification volume band.
Measures for the Standard Contract for Personal Information Export
The 2023 measures establish the standard-contract mechanism and prohibit volume splitting; the 2024 provisions supersede inconsistent route thresholds.
Section 2

2. Assess the transfer and execute the prescribed contract

Before export, complete the personal information protection impact assessment required by both PIPL and the standard-contract measures. It should address the exporter and recipient's purpose, scope, method, legality, legitimacy, and necessity; the scale, categories, and sensitivity; risks after export; the recipient's obligations and security capability; channels for individuals to exercise rights; and the effect of the recipient jurisdiction's laws and policies.

  • Use the standard contract in the CAC measures' annex. The parties may add terms, but added terms must not conflict with the standard contract.
  • Complete recipient due diligence against the commitments in the contract, including management and technical controls, incident handling, onward provision, retention and deletion, and individual-rights channels.
  • Give individuals the PIPL cross-border notice and obtain separate consent where required. The notice covers the overseas recipient's identity and contact details, purpose, method, personal information categories, and how individuals can exercise PIPL rights with the recipient.
  • Do not begin the personal information export until the standard contract is effective.
Sources for this answer
Measures for the Standard Contract for Personal Information Export
Articles 5-6 specify the export impact-assessment subjects, required CAC contract text, rule for additional terms, and requirement for the contract to take effect before export.
PRC Personal Information Protection Law
Articles 38-39 require an authorized export mechanism, protection meeting PIPL standards, the cross-border notice, and separate consent; Articles 55-56 require and define the impact assessment.
Section 3

3. File within 10 working days and control changes

File the effective standard contract and the personal information protection impact assessment report with the exporter's provincial cyberspace administration within 10 working days after the contract takes effect. Use the CAC Data Export Declaration System or another route accepted by the responsible provincial authority and follow the current filing guide for the package. The guide explains procedure; the binding measures set the duty. The exporter remains responsible for the truthfulness of the filed material and for the transfer after filing.

  • Retain the signed contract, impact assessment, route and exemption analysis, data-flow map, recipient review, notices and consent records, filing submission, receipt or correspondence, and implementation evidence.
  • Reassess and supplement or replace the contract, then complete the corresponding filing, if the export purpose, scope, category, sensitivity, method, storage location, recipient use or method changes, or if overseas retention is extended.
  • Apply the same change process if the recipient jurisdiction's personal-information law or policy changes in a way that may affect individuals' rights, or another event may affect those rights.
  • Track cumulative export counts. A later threshold crossing, important-data designation, critical-infrastructure status, new destination, or changed exemption facts can require a different route before the changed transfer proceeds.
Sources for this answer
Measures for the Standard Contract for Personal Information Export
Articles 7-8 require filing the contract and impact assessment within 10 working days, make the exporter responsible for filed materials, and list reassessment, contract, and re-filing triggers.
Provisions on Promoting and Regulating Cross-border Data Flow
Articles 7-10 support ongoing route monitoring and confirm that notice, separate consent, and impact-assessment duties continue for personal information exports.
CAC Personal Information Export Standard Contract Filing Guide, Second Edition
Official procedural guidance for the current declaration system, filing process, and optimized standard-contract filing materials.
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Primary sources

References and citations

PRC Personal Information Protection Law
cac.gov.cn
Referenced sections
  • Articles 38-39 require an authorized export mechanism, protection meeting PIPL standards, the cross-border notice, and separate consent; Articles 55-56 require and define the impact assessment.
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