---
title: "China's Data Property Rights Registration Guide Is Final: The Draft-to-Trial Diff"
author: "DCC Editorial"
published: 2026-07-04T07:30:00.000Z
url: https://datacompliancechina.com/posts/data-property-registration-guide-final-draft-diff/
description: "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."
tags: ["data-property-rights", "data-registration", "data-economy", "data-trading", "public-data", "data-assets", "practitioner-commentary"]
laws_cited: ["data-property-rights-registration-guide-draft", "data-foundation-system-opinions", "public-data-registration-interim-measures", "public-data-authorized-operation-specifications", "pipl", "dsl", "csl"]
domains: ["data-economy", "data-security", "personal-information"]
account: "ndb"
original_title: "国家数据局综合司关于印发《数据产权登记工作指引（试行）》的通知"
original_author: "National Data Administration, Comprehensive Department"
original_publication: "国家数据局 WeChat Official Account"
original_url: "https://mp.weixin.qq.com/s/cdOi12Q4eIbfLiI0r4szcQ"
source_language: "zh"
---

> **Source: Data Compliance China** — https://datacompliancechina.com/posts/data-property-registration-guide-final-draft-diff/ · China data law, translated and annotated for overseas counsel. Cite as: Data Compliance China, "China's Data Property Rights Registration Guide Is Final: The Draft-to-Trial Diff", https://datacompliancechina.com/posts/data-property-registration-guide-final-draft-diff/
> *Editor's Note - DCC.*
>
> On **1 July 2026**, the National Data Administration's Comprehensive
> Department issued the
> [Data Property Rights Registration Work Guide (Trial)](/laws/data-property-rights-registration-guide-draft/).
> The official WeChat article was published on **4 July 2026**. This brief
> compares that final Trial Guide against the **April 2026 public consultation
> draft**, which was released for comments from 3 April to 19 April 2026.
>
> The high-level architecture did not change: six chapters, 42 articles, five
> registration types, and the same three rights - the Right to Hold Data, the
> Right to Use Data, and the Right to Operate Data. The operative edge did
> change. The final Guide is more security-conscious, more registrar-controlled,
> more cautious on public data, and more explicit that the legal anchor is
> evidence preservation in the national system rather than the paper certificate
> alone.

## The one-line version

The consultation draft read like a market-infrastructure pilot. The final Trial
Guide reads like the first layer of a national registration regime: still
voluntary and still not an ownership code, but with stronger public-interest
filters, tighter control of registration institutions, clearer treatment of
derived data, a softer rule for public-data products, and a more concrete role
for registration certificates in data transactions, data-asset accounting,
financing and dispute evidence.

For overseas counsel, the most important point is negative: the final Guide still
does **not** create a unitary "data ownership" right. It operationalizes China's
existing three-rights vocabulary and creates a national record-and-certificate
mechanism around it. Registration is proof of attributed Data Property Rights and
their content; it is not a magic cure for an unlawful data source, an unresolved
title dispute, or a personal-information / important-data compliance gap.

## What did not change

Before reading the diff, keep the stable baseline clear.

- The Guide remains a **trial** work guide, not a statute or administrative
  regulation.
- It still applies by reference to Data Property Rights registration activities
  inside China, unless laws and regulations say otherwise.
- It still uses the **three-rights structure** from the Data 20 Articles: Right
  to Hold Data, Right to Use Data, and Right to Operate Data.
- It still treats those rights as **independent and non-exclusive**: one party
  may hold one or more of them, and different parties may hold the same right
  over the same data without mutual exclusion.
- It still uses the same registration workflow: application, acceptance, review,
  public announcement, objection handling, information evidence preservation and
  certificate issuance.
- It still recognizes five registration types: initial, transfer, change,
  renewal and deregistration.

That continuity matters because the final Guide is not a policy reversal. It is
an operational hardening of the same design.

## The article-by-article diff

| Area | Consultation draft | Final Trial Guide | Practical effect |
| --- | --- | --- | --- |
| Issuance posture | Public comments; NDA said implementation would proceed through pilots. | Formal issuance to provincial data authorities for reference implementation. | The instrument moves from policy testing to administrative roll-out, although still as a trial guide. |
| Article 1 | Legal basis was mainly Civil Code and Data Security Law; purpose focused on registration system and national integrated data market. | Adds transaction-cost reduction, "open, shared and secure" market language, the Data 20 Articles, PIPL and CSL. | Registration is now expressly tied to privacy, cybersecurity and data-security compliance, not only market circulation. |
| Article 2 | Covered data resources and data products. | Adds "except as otherwise provided by laws and regulations" and covers data products **and services**. | The Guide is broader in commercial form, but also expressly yields to higher or special rules. |
| Article 3 | Defined the three rights, registration institution and applicant. | Adds a definition of **derived data**. | The final text gives registrars a baseline for deciding when processing creates a separately registrable data object. |
| Article 4 | Principles: equality, voluntariness, standardization, fairness, good faith, convenience and efficiency. | Adds **security and order**, and a no-harm rule for law, national security, public interest and others' rights. | The registration system is not a neutral filing desk; it has a substantive safety gate. |
| Articles 5-6 | National "service platform" provided announcement, query, verification and objection services. | National "service system" aggregates registration results, supports institution management, and provides announcement, query and verification. | Terminology shifts from a platform interface to a state-managed infrastructure layer. |
| Article 7 | Eligible registrars included enterprise / public-institution and other legal persons; experience was in data-circulation services; reviewer team needed professional qualifications. | Narrows eligible entities to enterprise and public-institution legal persons, adds funding support for public institutions, allows data-registration or circulation experience, adds reviewer-management rules, and changes qualifications to professional capabilities. | Registrar admission becomes more controlled and more operationally realistic. |
| Article 10 | Required transparency, confidentiality, system operation and independence; banned profit-making data-provision activities. | Adds periodic disclosure of business handling and review-team construction, express trade-secret protection, and a broader ban on using registration convenience for improper benefit. | The final text worries less about registrars having any market business and more about conflict, leakage and abuse of procedural power. |
| Articles 11-13 | Annual evaluation and exit rules existed, with two months' exit notice and several preservation paths. | Adds risk-disposal language, requires five-working-day **advance** reporting for changes, adds rectification / exit consequences, extends exit notice to six months, and requires transfer of all materials and related data to a designated surviving institution after approval. | Continuity of registration records becomes a core regulatory concern. |
| Article 15 | "Market-circulable data" could be registered. Public-data products formed after authorized operation **shall** be registered after public-data-resource registration. | Deletes the general market-circulation sentence. Public-data products and services formed after authorized operation **may** be registered after public-data-resource registration. Public utilities are narrowed to public-utility enterprises. | The final Guide avoids turning public-data-product registration into a blanket mandatory second step. |
| Article 18 | Registrars could ask for supplementary materials and verify with interested parties or other relevant subjects. | Adds termination where the applicant cannot supplement evidence and the registrar cannot verify through lawful channels. | The review process now has a clean stop point for unverifiable cases. |
| Article 20 | Contract-acquired data required an agreement showing the applicant enjoyed the relevant rights; personal information and important data were reviewed separately. | Adds a cure path for unclear contracts; consolidates PI and important-data checks; adjusts derived-data comparison language. | The final text is more pragmatic on imperfect contracts but still refuses to let uncertainty pass silently. |
| Article 21 | For data collected by another person under civil contract, the principal needed the right to obtain or copy and transfer the data. | Narrows the condition to the right to obtain the relevant data. | The formal rule is less tied to physical copy / transfer language and more compatible with controlled-access structures. |
| Article 22 | Refusal covered data involving national security or state secrets, illegal source under laws / administrative regulations, unresolved attribution disputes, false materials and other statutory bars. | Refusal now covers registration that may harm national security, public interest or lawful rights and interests, source illegality under laws and regulations, and other law/regulation bars. | The refusal gate is broader and more risk-based. |
| Article 23 | Recorded limitations included agreed term / conditions, preservation measures, temporary controls and other matters the registrar considered necessary. | Adds matters required by laws and regulations. | Mandatory legal limitations must be recorded, not left to registrar discretion. |
| Articles 24-29 | Announcement, evidence preservation, certificate issuance and objections ran on the service platform; validity started from certificate issuance. | These run through the service system; registration is complete on evidence preservation; validity generally runs from completion of evidence preservation. | The authoritative record is the preserved system information, not the certificate as a standalone document. |
| Article 31 | Certificate could support data trading, data balance-sheet entry, financing, equity contribution, disputes and enterprise-support policies. | Sharpens to data-asset balance-sheet entry, financing guarantees, equity contribution by valuation, and preserves no-duplicate-review / no-duplicate-fee duties for data-circulation service institutions. | The final text is written for data-as-asset and data-finance workflows. |
| Articles 33-37 | Later registration types were handled by the initial-registration institution; later applications generally referenced the initial certificate; renewal was within six months before expiry. | Later registrations are handled by that institution **in principle**; applications reference the Data Property Rights registration certificate; renewal is available from six months before expiry through the day before expiry; deregistration notice must be written. | The final text adds flexibility while keeping certificate-centered continuity. |
| Articles 38-41 | Liability language used service-platform terminology and administrative-regulation references in places; transition allowed simplified review. | Aligns terminology to the service system and laws/regulations; adds preservation of relevant materials for simplified pre-existing registrations. | Transition is allowed, but the evidentiary record still needs to be kept. |

## 1. The final Guide broadens the policy basis and narrows the legal escape routes

Article 1 is more than a preamble edit. The draft justified the Guide mainly as
part of building the registration system and the national integrated data
market. The final text adds three signals.

First, it says registration should **reduce transaction costs**. That turns the
Guide toward due diligence, financing and dispute evidence, not just
administrative record-keeping.

Second, it describes the target market as **open, shared and secure**. The word
"secure" matters because security becomes visible throughout the final text:
Article 4 adds security and order as a principle; Article 22 broadens refusal;
Article 38 links registrar leakage to national security, public interest and
third-party rights.

Third, the legal-basis list now expressly includes PIPL and CSL, alongside the
Civil Code and DSL, and references the Data 20 Articles policy. This is a
useful correction. A registration certificate cannot sanitize a personal
information processing defect or a cybersecurity defect; the registrable right
must sit on a lawful data source.

Article 2 moves in the same direction. The final text covers data products
**and services**, which matters for API, model-output, data-clean-room and
trusted-data-space business models. But it also adds an "unless laws and
regulations provide otherwise" caveat. So the Guide expands the commercial
surface while making clear that sectoral, public-data, PI, important-data and
cybersecurity rules can override or qualify registration practice.

## 2. Derived data is now a defined registration object

The draft already used derived data in the rights-clarity rules. The final Guide
adds the definition in Article 3. That is a significant drafting improvement
because derived data is the pressure point in China's three-rights design.

Under the final text, derived data is not merely cleaned data, formatted data or
copied data. It is data formed by a processor that already has the Right to Use
Data over the underlying data; the processor must protect lawful rights and
interests of all parties; and the processing must produce substantive changes in
content, form or structure that significantly increase value.

This definition does two jobs.

First, it gives registrars an evidentiary question: can the applicant show the
input data, the legal basis for using it, the processing path, the output data,
and the value uplift?

Second, it prevents a simple laundering move. A party cannot take data from a
weak or unlawful source, perform light processing, and treat the result as a new
property-rights object. Articles 20 and 21 still require a lawful source and a
clear right to use the underlying data.

## 3. The system is now built around security and public-interest refusal

Article 4 and Article 22 are the clearest signs that NDA does not want
registration to become a purely private-law certificate factory.

The draft's Article 4 listed procedural virtues. The final Article 4 adds
"security and order" and says registration activities must not violate law,
harm national security, harm the public interest, or infringe others' lawful
rights and interests.

Article 22 then converts that principle into a refusal rule. The draft refusal
standard included data involving national security or state secrets. The final
text is broader: if the registration may endanger national security, public
interest, or lawful rights and interests of individuals or organizations, the
institution must refuse registration.

That wording matters for three categories of hard case:

- **Scraped public data** where technical-measure circumvention, terms breach,
  unfair competition, or substitution risk is present.
- **Personal information or important data** where the source chain cannot show
  valid processing, security, consent / alternative basis, or classification and
  grading compliance.
- **Disputed commercial data** where the applicant can describe the dataset but
  not resolve competing claims by upstream contributors, co-developers,
  entrusted processors or data-space participants.

The final Guide therefore makes the registrar's job more substantive. A
registrar is not adjudicating property title like a court, but it also cannot
register known red flags as if the certificate were just a timestamp.

## 4. "Service platform" became "service system"

Across the Guide, the draft's National Data Property Rights Registration Service
Platform becomes the National Data Property Rights Registration Service System.
This sounds minor, but the change is consistent.

In the draft, Article 6 described a platform that provided announcement, result
query, verification and objection services. The final Article 6 describes a
system that aggregates registration results, provides announcement / query /
verification services nationwide, and supports registrar management.

The practical read is that NDA is building the national layer as governance
infrastructure, not merely as a web portal. The evidence-preserved information in
the system wins if it conflicts with the certificate. Registrars must connect to
the system. Institution information is submitted in the system. Public
announcements and objections are routed through the system. Liability provisions
also refer to the system.

For transactions, this matters because diligence should not stop at the PDF or
paper certificate. The reliable evidence point is the preserved system record,
the certificate code, the issuing institution, and the consistency between the
certificate and system information.

## 5. Registrar governance is much tougher

The most detailed edits are in Chapter 2.

**Entry conditions.** The draft allowed "enterprise and public-institution and
other legal persons." The final text narrows this to enterprise and
public-institution legal persons. Enterprise legal persons still need paid-in
registered capital of at least RMB 100 million. Public-institution legal persons
now need funding support appropriate to the registration business. This closes a
loose "other legal person" category and makes public-institution capacity part of
the qualification test.

**Experience and people.** The draft required at least two years of data
circulation service experience. The final text allows two years of data
registration or data-circulation related service experience. That is broader and
probably more realistic. But it also adds a registration-reviewer management
system and requires the review team to have professional capabilities, not just
formal qualifications. NDA appears to be looking for operational competence,
not credential formalism.

**Disclosure and confidentiality.** Article 10 now requires periodic disclosure
of business-handling status and full-time review-team construction. It also adds
trade-secret protection to the confidentiality obligation. That addition is
practical: applicants will submit samples, source documentation, contracts,
data-product descriptions and rights-allocation evidence. Leakage would be
commercially sensitive even where no personal information is involved.

**Conflict controls.** The draft banned registrars from profit-making
data-provision activity. The final text instead bars conduct affecting fairness
or independence, using registration convenience for improper benefit, and
applying for registration in one's own institution. This is a smarter
conflict-control design. A data exchange or data-service body may have market
roles; the key regulatory concern is whether the registrar uses its procedural
position to favor itself, capture applicants or bundle services.

**Annual evaluation and risk disposal.** Article 11 keeps the reporting dates:
registrars report annual business to the provincial authority by 31 March, and
provincial authorities submit evaluation materials to NDA by 30 April. The final
text adds that risks found through evaluation should be handled promptly and
properly. That pushes annual evaluation from paperwork into supervisory action.

**Changes and exit.** Article 12 is materially stricter. The draft required
reporting within five working days after specified changes. The final text
requires reporting five working days **in advance** where key information or
major matters affect the qualification and operating requirements. If the
institution no longer meets the conditions, it must rectify or exit.

Article 13 is even more important. Exit notice moves from two months to six
months. The draft had multiple preservation paths depending on whether the
legal person survived, merged, went bankrupt or dissolved. The final text
requires complete transfer of all registration materials and related data to a
surviving registration institution designated by the provincial authority after
NDA approval. Certificates already issued remain unaffected, and prior liability
is not wiped out.

This is the final Guide's strongest institutional-continuity move. If
registration is to support financing, disputes and data-asset recognition, the
evidentiary archive cannot disappear with the registrar.

## 6. Public data was deliberately softened

Article 15 is one of the most commercially important changes.

The draft opened with a broad sentence: market-circulable data could be
registered. The final text deletes that sentence and frames Article 15 only as a
public-data-resource rule. That avoids a confusing overlap with Article 2 and
with the general voluntary-registration logic.

For public data, the final Guide preserves the no-registration rule for data
collected or produced by Party and government organs in performing statutory
duties, and for certain data collected by other bodies because statutory duties
require it. That is consistent with the idea that primary public data resources
are not privately registered as Data Property Rights.

The key change is public-data products and services formed after authorized
operation. The draft said they should be registered for Data Property Rights
after public-data-resource registration. The final text says they **may** be
registered after public-data-resource registration is completed.

That is a real policy choice. It means Data Property Rights registration is not
automatically mandatory for every public-data authorized-operation output. The
prior public-data-resource registration remains the gateway, but the downstream
property-rights registration is conditional and voluntary. For local governments,
authorized operators and exchanges, this reduces the risk of a mechanical
"register twice" rule and leaves room for product type, transaction structure
and local implementation.

The public-utilities item is also narrowed. The draft referred to public utility
enterprises and public institutions. The final text refers to public utility
enterprises. That matters for hospitals, schools and other public institutions:
their data may be governed more directly by public-data, health, education,
PI and sectoral rules rather than treated through the public-utility enterprise
item.

## 7. Review becomes more evidence-driven, but also more workable

Articles 18, 20 and 21 are where applicants will feel the final Guide day to
day.

Article 18 adds a termination route. If the applicant cannot supplement
supporting materials and the registrar cannot verify through lawful channels,
registration may be terminated. That is not the same as a refusal on the merits,
but it prevents registrars from keeping an unverifiable file open indefinitely.

Article 20 is more nuanced. For contract-acquired data, the draft asked whether
the relevant agreement stipulated that the applicant enjoyed the relevant Data
Property Rights. The final text adds a cure path: if there is no stipulation or
the stipulation is unclear, the applicant may be asked to supplement the
stipulation, or the registrar may make a reasonable and prudent judgment based
on the actual circumstances.

This is practical because Chinese data contracts written before the Data 20
Articles vocabulary often did not say "Right to Hold Data," "Right to Use Data"
or "Right to Operate Data." They may instead speak in older terms: data supply,
data service, API access, entrusted processing, exclusive cooperation,
commercialization authorization, or revenue sharing. The final text lets
registrars deal with that legacy reality without pretending every old contract
is void for lack of perfect vocabulary.

But the cure path is not a free pass. Where entitlement is unclear, the applicant
will need supplemental documentation, amendments, confirmations, transaction
records, technical access evidence, data-source evidence or other materials that
support the rights claim.

Article 20 also consolidates the personal-information and important-data review
items into a single item tied to PIPL, DSL and other laws and regulations. This
is cleaner and avoids treating PI and important data as unrelated silos.

Article 21 narrows one important rights-clarity scenario. Under the draft, where
subjects authorized another person under civil contract to collect data they
caused to be produced, they needed the right to obtain or copy and transfer the
data. The final text requires the right to obtain the relevant data. That is
more compatible with controlled-access models, API delivery, trusted data
spaces and privacy-preserving computation, where a party may obtain access or
outputs without a conventional copy-transfer event.

## 8. Evidence preservation now starts the validity clock

The draft placed the certificate-validity rule in Article 27: the registration
certificate took effect from issuance and was generally valid for no more than
five years. The final Guide moves the validity rule into Article 26. Registration
is complete when registration information is evidence-preserved in the national
system, and the validity period generally runs from that date.

That is one of the cleanest operational changes.

It makes the preserved system record the legal anchor. The certificate still
matters. Article 27 still requires the certificate to use the unified format and
coding requirements and bear the registrar's special seal. But if the certificate
content conflicts with information preserved in the national system, the system
information prevails.

For diligence, this points to a three-step check:

- verify the certificate code and issuing institution;
- check the national system record where available; and
- confirm the evidence-preservation date, because that date controls the
  ordinary validity period.

The change also matters for renewals. The renewal window now runs from six
months before expiry through the day before expiry, and the expiry should be
calculated from the evidence-preservation-based validity period, not merely from
the date printed on a certificate if the two ever diverge.

## 9. The certificate is more finance-facing than before

Article 31 keeps the general rule that a Data Property Rights registration
certificate may serve as proof of the attribution and content of Data Property
Rights in specified activities. The changes are in the examples.

The draft referred to data balance-sheet entry, financing and equity
contribution. The final Guide sharpens this to **data-asset balance-sheet
entry**, **financing guarantees**, and **equity contribution by valuation**.

That wording tracks the way China's data-asset policy has been developing:
registered rights are expected to support accounting recognition, pledge or
guarantee-style financing, valuation work, and contribution of data-related
interests into companies. The certificate is not made dispositive in every
case, but it becomes a standardized proof object for market actors who otherwise
struggle to diligence intangible data interests.

The final text also preserves an important market-infrastructure rule: data
circulation service institutions should accept certificates issued under the
Guide and, without legitimate reason, should not conduct duplicate review or
charge duplicate fees.

This is aimed at national mutual recognition. If it works, a dataset registered
through one qualified institution should not have to be re-reviewed from scratch
by every exchange, trading platform, financing institution or local service
provider. If it fails, registration becomes one more local paperwork layer.

## 10. Later registration types are more flexible, but certificate continuity remains

Chapter 4 is mostly stable, but the final edits matter.

The draft said later registration types for the same data were handled by the
institution that handled initial registration. The final text adds "in
principle." That small qualifier gives regulators room to deal with registrar
exit, regional coordination, mergers, capacity problems or other operational
exceptions.

Transfer, change, renewal and deregistration applications now refer generally
to the Data Property Rights registration certificate rather than the initial
registration certificate. That is cleaner because a dataset may have gone
through transfer or change before a later renewal or deregistration.

For deregistration, the final text requires written notice to the original
applicant where the registrar proactively deregisters. This is a modest
procedural-protection addition, but important because deregistration may affect
transactions, financing, balance-sheet treatment and disputes.

## What this means for the main actors

**For registration institutions:** build the evidence file, not just the intake
form. The final Guide expects reviewer management, trade-secret protection,
system connection, periodic disclosure, annual evaluation, risk disposal,
advance change reporting and a six-month exit-transfer plan. Institutions that
also operate exchanges or data services need visible conflict controls.

**For applicants:** the application package should be built around the source
chain. Expect to evidence lawful collection or acquisition, contractual rights,
public-data-resource registration where relevant, PI / important-data
compliance, and why any derived data is materially different and higher value.
If old contracts do not use the three-rights vocabulary, prepare supplemental
rights confirmations rather than relying on broad service language.

**For public-data operators:** the final text gives more room. Public-data
products and services formed after authorized operation may be registered after
public-data-resource registration, but they are not automatically forced into
Data Property Rights registration. The right answer will depend on transaction
plans, financing needs, exchange listing, local data-bureau expectations and
the structure of the authorized-operation agreement.

**For exchanges and data-circulation service institutions:** the certificate is
designed to reduce duplicate review and duplicate fees. But reliance should be
bounded: verify system consistency, certificate validity, scope of registered
rights, recorded limitations, and any unresolved objections or disputes.

**For banks, investors and accountants:** the final text is deliberately written
for data-asset recognition and financing. But the certificate proves attributed
rights and content; it does not by itself prove valuation, economic benefit,
control for accounting purposes, absence of PI risk, or enforceability of a
security interest. Treat it as an important diligence artifact, not as the whole
diligence package.

**For overseas counsel:** do not translate the certificate as "ownership title."
The better read is a standardized, nationally recognized evidence object for
specified Data Property Rights under China's three-rights structure. That makes
it useful in deals, financing and disputes, but still dependent on source
legality, contract entitlement, public-data rules, PI / important-data
compliance and the preserved system record.

## DCC sources

- **Final instrument:** National Data Administration, Comprehensive Department,
  《国家数据局综合司关于印发<数据产权登记工作指引（试行）>的通知》, issued on
  1 July 2026 and published on the 国家数据局 WeChat Official Account on
  4 July 2026 -
  [original Chinese article](https://mp.weixin.qq.com/s/cdOi12Q4eIbfLiI0r4szcQ).
- **Consultation draft:** National Data Administration, Comprehensive Department,
  《数据产权登记工作指引（试行）》（公开征求意见稿）, released for public comment
  on 3 April 2026, with comments due by 19 April 2026 -
  [Xinhua mirror of the NDA WeChat release](https://app.xinhuanet.com/news/article.html?articleId=2026040317b587121c5f492fa8c3035ef9b02c5f).
- **DCC working text:** the
  [Data Property Rights Registration Work Guide (Trial)](/laws/data-property-rights-registration-guide-draft/)
  entry on DCC, updated to the final Trial Guide and cross-checked against the
  April consultation draft.

*Not legal advice. This is DCC's structured comparison of the final Trial Guide
against the consultation draft, written for overseas readers and practitioners.*