---
title: "Two Registrations, One Word: China's New Data-Asset Standards and the Line Between 登记 and 登记"
author: "DCC Editorial"
published: 2026-07-24T09:00:00.000Z
url: https://datacompliancechina.com/posts/data-asset-standards-two-registrations/
description: "On 2 July 2026 China issued two national standards for data as an asset — GB/T 47949-2026 (classification and codes) and GB/T 47950-2026 (registration guidance) — both effective 1 September 2026. They give data assets a fixed place in the asset-classification code system (block A0806020000, including a first-ever asset code for AI-training multimodal data measured in tokens) and a step-by-step model for putting data on an organization's own books. The trap for overseas counsel is the word 登记 (registration): these MOF/SAC standards register data as an asset internally, while the National Data Administration's Data Property Rights Registration Work Guide (Trial), finalized 1 July 2026, registers rights in data externally through a certificated institution. Same word, two regimes, two artifacts, two purposes. This DCC brief separates them, reads the two standards for what they require, and explains why the 入表 (balance-sheet entry) vs 确权 (rights confirmation) distinction keeps tripping up data-asset deals."
tags: ["data-assets", "data-property-rights", "data-registration", "data-economy", "data-on-balance-sheet", "national-standard", "ai-training-data", "practitioner-commentary"]
laws_cited: ["gbt-47950-data-asset-registration-guidance", "gbt-47949-data-asset-classification-codes", "data-property-rights-registration-guide-draft", "data-foundation-system-opinions", "dsl", "pipl"]
domains: ["data-economy", "data-security"]
source_language: "zh"
---

> **Source: Data Compliance China** — https://datacompliancechina.com/posts/data-asset-standards-two-registrations/ · China data law, translated and annotated for overseas counsel. Cite as: Data Compliance China, "Two Registrations, One Word: China's New Data-Asset Standards and the Line Between 登记 and 登记", https://datacompliancechina.com/posts/data-asset-standards-two-registrations/
> *Editor's Note — DCC.*
>
> On **2 July 2026** the State Administration for Market Regulation and the
> Standardization Administration of China issued two recommended national
> standards for data held as an asset —
> [GB/T 47949-2026 *Classification and Codes for Data Assets*](/laws/gbt-47949-data-asset-classification-codes/)
> and
> [GB/T 47950-2026 *Guidance for Data Assets Registration*](/laws/gbt-47950-data-asset-registration-guidance/).
> Both take effect on **1 September 2026**. They were drafted by the Ministry
> of Finance's Asset Management Department and the China National Institute of
> Standardization under the National Technical Committee on Asset Management
> Standardization (SAC/TC 583).
>
> This is DCC's own reading of the two standards. The single thing to carry
> away: **both use the word 登记 ("registration"), and they are not the same
> act as the registration in the National Data Administration's
> [Data Property Rights Registration Work Guide (Trial)](/laws/data-property-rights-registration-guide-draft/)**
> — finalized on 1 July 2026, which DCC covered in
> [the draft-to-Trial diff](/posts/data-property-registration-guide-final-draft-diff/).
> One registers data as an **asset on your own books**; the other registers
> **rights in data** with an outside institution that issues a certificate.
> Conflating them is the central error, and it is easy to make because the
> Chinese term is identical.
>
> **— Not legal advice.**

## The same word, twice

Chinese data policy now contains two things called 数据…登记, and a foreign
reader who meets them a week apart can be forgiven for assuming they are one
regime described twice. They are not. They come from different ministries,
answer different questions, and produce different pieces of paper.

- **数据资产登记 — data-asset registration.** The subject of the two new
  standards. It is an act of **asset management**: an organization records a
  data resource it has confirmed to be an asset onto its own asset register
  (资产台账) and into its own accounting books. Nothing is filed with anyone.
  The MOF/SAC standards tell you how.
- **数据产权登记 — data property-rights registration.** The subject of the
  NDA's Trial Guide. It is an act of **rights confirmation**: an applicant
  asks an NDA-catalogued registration institution to review who holds which of
  the three data rights (hold / use / operate), which then publicly announces
  the claim, preserves the evidence, and issues a **certificate**.

Put side by side:

| | Data-asset registration (GB/T 47950) | Data property-rights registration (NDA Trial Guide) |
|---|---|---|
| Who registers | The organization itself, internally | An NDA-catalogued registration institution |
| Question answered | *Is this an asset of ours, and what is it worth?* | *Who holds which right over this data?* |
| Output | Data asset card, asset register, accounting books | A publicly announced, evidence-preserved rights certificate |
| Governing instrument | GB/T 47950 + [GB/T 47949](/laws/gbt-47949-data-asset-classification-codes/); MOF data-asset policy | [Data Property Rights Registration Work Guide (Trial)](/laws/data-property-rights-registration-guide-draft/) |
| Legal effect | Internal management, accounting, reporting | External proof of attribution in transactions, financing, disputes |
| Trigger | Follows from asset-management duties | Voluntary application |

They are not rivals — they interlock. The data asset card defined by GB/T
47950 has a field for *whether ownership has been registered*, and the thing
that fills that field is precisely the NDA certificate. An organization
pursuing full data-asset capitalization will generally end up doing **both**:
confirm and book the asset under the MOF/SAC track, and confirm the rights
under the NDA track. But they are two projects, run by two internal owners,
against two rulebooks.

## What the two standards actually do

**[GB/T 47949](/laws/gbt-47949-data-asset-classification-codes/) gives data
assets a code.** It slots them into China's existing asset-classification
system as intangible assets: the whole population of data assets now lives
under the block **A0806020000** — intangible assets (08) → information-and-data
intangible assets (06) → data (02). Below that, the standard's Clause 6 table
splits data assets into three classes by structure — **structured,
semi-structured, unstructured** — and fourteen sub-classes, each with a
prescribed unit of measure (megabytes, records, images, tracks, and so on).
It classifies by what the data technically *is*, not by sector or use, and it
is careful to say it does **not** change how data assets are defined or
classified for accounting purposes.

**[GB/T 47950](/laws/gbt-47950-data-asset-registration-guidance/) gives them a
process.** It sets three principles — security, compliance, traceability —
routes the [Data Security Law](/laws/dsl/) and PIPL into the registration
process as a *precondition* (a data asset whose source is non-compliant is not
registrable), and allocates the work across four internal functions: the data
business owner, asset management, accounting, and — notably — the
data-technology/informatization function, which runs the compliance review at
every stage. Registration is dual: an **asset register** built from a data
asset card, and the **accounting books**, kept in parallel. Classification and
units of measure on the card come straight from GB/T 47949.

## The one genuinely new thing: an asset code for training data

Buried in the GB/T 47949 table is **A0806020307 — AI-training multimodal
data**: pre-training and fine-tuning corpora, image-text / video-text /
audio-text aligned samples, synthetic labelled data, multi-source
heterogeneous data. So far as DCC is aware, this is the **first time a Chinese
national asset-classification standard has given AI training corpora a
dedicated asset code** — and its unit of measure is **megabytes and tokens**.

That token count is not decoration. If a Chinese counterparty is capitalizing
its training data, this is the code line its asset register will carry and the
quantity the register expects to see. For any cross-border AI deal where
training data is part of the consideration or the diligence, "how many tokens,
under which code, on whose books" is now a question with a standardized answer
format.

## Why 入表 and 确权 keep getting mixed up

The reason the two registrations are so easy to confuse is that the underlying
concepts they serve are *also* routinely confused: **入表** (balance-sheet
entry) and **确权** (rights confirmation).

- **入表** is an accounting question — can this data resource be recognized as
  an asset, and at what value? It is governed by the Ministry of Finance's
  *Interim Provisions on the Accounting Treatment of Enterprise Data Resources*
  (财会〔2023〕11号) and the data-asset management notices. GB/T 47950 is the
  operating manual for the register that sits behind 入表.
- **确权** is a rights question — who owns or holds what in the data. It is
  governed by the [Data 20 Articles](/laws/data-foundation-system-opinions/)
  three-rights framework and, operationally, by the NDA Trial Guide.

You can do one without the other, and the gap between them is exactly where
data-asset deals get fragile. DCC's brief on
[Xu Ke's account of when data becomes an asset](/posts/xu-ke-data-asset-identification/)
works through the definitional side of 入表 — the narrow-sense test (owned or
controlled, generates economic benefit, reliably measurable) that GB/T 47950's
"data asset confirmation" (数据资产确认) now codifies as the gate to initial
registration. The registration standards handle the *asset* half of that
sentence; the NDA guide handles the *rights* half. Neither resolves the deeper
contest — whether a data right is a property right at all — that the Data 20
Articles deliberately left open.

## The quiet innovation: the subsidiary record

One feature of GB/T 47950 deserves a flag because it is genuinely useful:
the **data asset subsidiary record** (数据资产备查簿). The standard's process
is gated on *confirmation* — a data resource that meets the asset-confirmation
conditions goes to initial registration; one that does **not yet** meet them is
entered into the subsidiary record instead of being lost.

That gives organizations a defined place to park data that is real and managed
but not yet bookable — data whose ownership is unsettled, whose economic
benefit is not yet demonstrable, or whose value cannot yet be measured
reliably. Without it, the practical choice would be premature recognition or
invisibility. For a firm building toward capitalization, the subsidiary record
is the on-ramp: it is where a data resource waits while the 确权 question is
resolved on the NDA track and the 入表 test is worked toward on this one.

## For overseas counsel

Three practical points:

1. **Do not treat a data-property certificate and an asset entry as the same
   assurance.** An NDA certificate answers *who holds the rights*; a GB/T 47950
   asset register answers *what the counterparty booked*. Diligence that wants
   both must ask for both — and check whether the asset card's
   "ownership registered?" field points to an actual certificate.
2. **The compliance gate is real and it is upstream.** GB/T 47950 makes
   source compliance — [DSL](/laws/dsl/), PIPL, important-data rules — a
   precondition of registration, mirroring the source-compliance review the
   NDA guide imposes on the rights side. Data with a defective provenance is
   registrable on neither track.
3. **Watch the training-data code.** A0806020307 standardizes how AI training
   corpora appear as assets. If your matter involves Chinese training data as
   value — licensing, contribution, securitization — expect it to surface in a
   standardized asset form, measured in tokens, from 1 September 2026 onward.

Both standards are recommended (GB/T), not mandatory (GB) — they bind through
adoption in asset-management and procurement practice rather than by force of
law. But given that the Ministry of Finance drafted them and its own
administrative-institution data-asset notice (财资〔2024〕1号) already directs
public bodies to register and report data assets, adoption in the state sector
is not really optional, and the enterprise sector tends to follow the MOF
register format regardless.

**— Not legal advice.**