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DCC · DATA COMPLIANCE CHINA China data law, for overseas counsel.
§ BRIEFINGS · PAGE 04

Every brief.

The full run, most recent first.

  • § 19 · AI-COMPANION

    Doubao, Qwen, and NetEase Pull AI Companions Ahead of July 15 — Is Delisting to 'Stay Safe' the Right Move?

    Days before the AI Anthropomorphic Interaction Measures take effect on July 15, 2026, Doubao, Qwen, and NetEase removed agent-style companion features — and at least one AI company had already received a question list from regulators. This translated report from 竞争秩序场 (reporter Wang Jun) maps why the industry calls the rules right in direction but hard in practice: scoping ambiguity around role-play on general-purpose models and UGC agent builders, 'capability regulation' that runs through model training and operations rather than content filters, the psychology-grade judgment needed to spot excessive emotional dependence, and expert warnings that clumsy intervention or perceived surveillance of intimate chats could do its own harm. Includes proposals for public safety-capability toolkits for smaller developers.

    ai-companion · anthropomorphic-interaction · enforcement-signals
  • § 20 · AI-COMPANION

    Ten Questions Before July 15: A Compliance Q&A on China's AI Anthropomorphic Interaction Measures

    Two days before the Interim Measures for the Management of AI Anthropomorphic Interaction Services take effect on July 15, 2026, compliance practitioners Chen Huan and Li Qiyao distill the final text into ten questions AI companies keep asking: what counts as an anthropomorphic interaction service (and what is excluded), the content red lines, training-data duties, mandatory registration fields including age and emergency contacts, the two-hour usage reminder, the ban on virtual intimate relationships for minors, the separate-consent gate on training with sensitive interaction data, the five security-assessment triggers, and the penalty ladder topping out at RMB 200,000 where life and health are harmed.

    ai-companion · anthropomorphic-interaction · minors-protection
  • § 21 · CYBERSECURITY

    NFRA Opens Consultation on Banking and Insurance Cybersecurity Measures: 72 Articles, a Four-Tier Incident Scale, and a Hard CII Chapter

    The National Financial Regulatory Administration is consulting on the Measures for the Administration of Cybersecurity in the Banking and Insurance Sectors — a 72-article draft that would give banks, insurers, and financial holding companies a single cybersecurity rulebook under the CSL, DSL, PIPL, and CII Regulations. It fixes board-level responsibility, a six-month log-retention floor, annual penetration testing, a four-tier incident scale with a two-hour reporting clock, and a dedicated critical-information-infrastructure chapter with a one-hour reporting deadline, domestic-operation and disaster-recovery requirements, and annual procurement-list reporting. Comments close August 10, 2026.

    cybersecurity · financial-sector · critical-information-infrastructure
  • § 22 · CROSS-BORDER

    The Negative-List Map, Region by Region: Ten Zones, Two Models, and the Year Data Export Went Province-Wide

    As of July 2026, ten Chinese regions — nine free-trade zones plus the Hainan Free Trade Port — have published data-export negative lists under Article 6 of the 2024 Cross-border Data Flows Provisions, and this year Beijing and Shanghai took the mechanism province- and city-wide, off the FTZ footprint entirely. DCC's roundup maps the full set: which sectors each zone lists (from Tianjin's 13 commodity categories to Guangdong's smart-manufacturing and personal-credit fields, Chongqing's intelligent-connected-vehicle chain, and Jiangsu's biopharma-only list), the two management models that have crystallized — pre-export filing versus Shanghai and Guangdong's 'transfer-first, report-after' — and how an overseas team should read the map. Compiled from the CAC's national negative-list index and each region's official notice, and paired with DCC's new downloadable negative-list registry.

    cross-border · negative-list · ftz-negative-list
  • § 23 · E-COMMERCE-LAW

    China's 2026 Draft E-Commerce Law Amendment: From Marketplace Transactions to Platform-Economy Governance

    On July 4, 2026, the State Administration for Market Regulation and the Ministry of Commerce released the Draft Amendment to the E-Commerce Law for public comment, with comments due August 4, 2026. The draft has 20 articles and, according to the official notice and Xinhua Q&A, moves in five directions: expanding the law's adjustment scope beyond platforms and in-platform operators to other platform-economy participants; strengthening the platform responsibility system with richer, more graduated regulatory tools; building an integrated supervision mechanism for cross-sector platform operations, including consistent online/offline business supervision and stronger department and central-local coordination; targeting prominent illegal conduct in e-commerce; and deepening open cooperation by aligning rules, regulation, management and standards with international practice, supporting industry self-discipline and orderly outbound expansion, and adding countermeasure tools to protect Chinese enterprises. DCC reads the amendment as an attempt to reposition the E-Commerce Law from a transaction/platform statute into a platform-economy governance statute, with operational implications for platform rulemaking, merchant and worker protection, consumer governance, data/network security clauses, competition compliance, and outbound platform expansion.

    e-commerce-law · platform-economy · platform-governance
  • § 24 · DATA-PROPERTY-RIGHTS

    China's Data Property Rights Registration Guide Is Final: The Draft-to-Trial Diff

    On 1 July 2026, the National Data Administration issued the Data Property Rights Registration Work Guide (Trial), converting its April 2026 consultation draft into China's first national framework for registering the Right to Hold Data, Right to Use Data and Right to Operate Data. The final text keeps the same six-chapter, 42-article structure, but the diff is not cosmetic: security and public-interest gates are stronger; derived data is now defined; the national infrastructure shifts from a service platform to a service system; registrars face tighter qualification, disclosure, annual-evaluation, change-reporting and exit rules; public-data registration is softened from mandatory to conditional/voluntary wording; unclear contractual entitlement receives a cure path; evidence preservation, not certificate issuance, now starts the validity period; and certificate use is sharpened for data-asset balance-sheet entry, financing guarantees and valuation-based equity contribution.

    data-property-rights · data-registration · data-economy
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