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China Privacy Law personal information standard contract filing workflow

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

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

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Oct 15, 2026
3 sections4 primary sources
Overview

A processor that is not a critical information infrastructure operator (non-CIIO) must use the Cyberspace Administration of China (CAC) 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 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 flows with neither personal information nor important data, 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.
Section 2

2. Assess the transfer and execute the prescribed contract

Before export, complete the 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 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 is effective.
Section 3

3. File within 10 working days and control changes

File the effective and the 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.
Operationalize the requirement

Prepare and maintain the standard-contract filing

Assign the filing owner and keep the route decision, assessment, effective contract, submission receipt and change reviews together.

Research workflow
Map official sources to evidence

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

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Talk to Sorena
Review the China route

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

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Primary sources

References and citations

Measures for the Standard Contract for Personal Information Export
cac.gov.cn4 citations
Referenced sections
  • Binding measures for assessment contents, contract form and effect, 10-working-day provincial filing, responsibility for materials, and change-triggered re-filing.
  • The 2023 measures establish the standard-contract mechanism and prohibit volume splitting; the 2024 provisions supersede inconsistent route thresholds.
  • 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.
Show 1 more
  • 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
cac.gov.cn3 citations
Referenced sections
  • Current CAC provisions for exemptions and the volume thresholds that determine security assessment, standard contract or certification.
  • Articles 2-8 provide the current important-data rule, exemptions, security-assessment triggers, and standard-contract or certification volume band.
  • Articles 7-10 support ongoing route monitoring and confirm that notice, separate consent where required, and impact-assessment duties continue for personal information exports.
CAC Personal Information Export Standard Contract Filing Guide, Second Edition
cac.gov.cn2 citations
Referenced sections
  • Current official procedural guidance for the online filing route, process, and package; the binding measures and 2024 provisions control the legal test.
  • Official procedural guidance for the current declaration system, filing process, and optimized standard-contract filing materials.
PRC Personal Information Protection Law
cac.gov.cn2 citations
Referenced sections
  • Binding law for overseas-transfer mechanisms, protection duties, individual notice, separate consent where required, and the impact assessment.
  • Articles 38-39 require an authorized export mechanism, protection meeting PIPL standards, the cross-border notice, and separate consent where required; Articles 55-56 require and define the impact assessment.

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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.