Editor’s Note — DCC.
This brief covers a single new instrument — the Guangdong Province Public Data Resource Authorized-Operation Price Management Measures (《广东省公共数据资源授权运营价格管理办法》), issued 12 May 2026 by the Guangdong Development and Reform Commission (DRC) and the Guangdong Provincial Administration of Government Services and Data (省政务服务和数据管理局, the provincial “政数局”). DCC works from two WeChat sources that carry the same instrument from opposite ends: the full 20-article text, reposted by the independent channel 数据行者X (DataWalker) (original), and the official departmental interpretation (部门解读) sourced from the Guangdong DRC and reposted by the PPP-advisory firm 砖济咨询 (Shenzhen Brick-Economy Public Consulting) (interpretation). Neither channel adds analysis of its own; the substance is official. The analysis below — the “regulated-utility” reading, the comparison to rate-of-return tariff-setting, and the operational takeaways — is DCC’s.
One framing note for overseas readers. China’s public-data regime is layered: the national Authorized-Operation Implementation Specifications and Registration Interim Measures (both NDRC + NDA, January 2025) set the floor, and provinces issue the binding implementation rules. The price mechanism has its own national parent — the NDRC/NDA Notice on Establishing a Price-Formation Mechanism for the Authorized Operation of Public Data Resources (《关于 建立公共数据资源授权运营价格形成机制的通知》, 发改价格〔2025〕65号) — and Guangdong is among the first provinces to operationalise it. The Measures sit inside Guangdong’s “1+3” public-data policy system and run for a five-year term from issuance.
What the Measures actually price
The object of the rule is narrow and specific: the public-data operation service fee (公共数据运营服务费). This is the fee an operating institution (运营机构) — a body that has obtained authorization through the proper procedure — may charge when it governs and develops public data resources within its authorized scope and fairly provides data products and services to the market (Article 3).
Two gating conditions sit in front of the fee, and both tie back to the national regime DCC has covered before:
- the underlying public data resources must be registered with the registration body designated under Guangdong’s public-data registration rules (the provincial implementation of the Registration Interim Measures); and
- the data products and services must be formed under the authorized-operation rules, registered, and listed on the catalogue of public-data products and services that support industry development.
In other words, the price rule only switches on after a firm is inside the gate that DCC’s earlier brief — Inside the Gate: How Enterprises Can Compliantly Process, Operate, and Trade Public Data — describes. The Measures answer the question that regime left open: once you are an authorized operator with a listed product, how much can you charge, and who decides?
The headline mechanism: government-guided pricing, not market pricing
The fee is placed under classified-and-tiered management and government-guided pricing (分类分级管理、政府指导定价 — Article 4). It is not left to the market. The official interpretation is explicit about why: public data resources carry both a public-welfare attribute and economic potential, so the regulator wants a price that keeps operators “healthy and sustainable” while preventing them from forming monopoly profits (防止其形成垄断利润). That sentence is the whole policy in one line — the operator is being treated as a franchised infrastructure monopoly, not as a competitive vendor.
The decision rights split by level of authorization:
- Province-level authorization. The Guangdong DRC, together with the data authority, verifies the operator’s maximum permitted revenue (最高准许收入). Within that ceiling, the data authority sets ceiling tariffs (上限收费标准) for each class of product and service (copying the DRC). The operator then sets specific charges at or below those ceilings.
- City/county-level authorization. The prefecture-level city government sets the charging standards; its DRC and data authority verify the maximum permitted revenue; the data authority sets ceilings within it, reported to the city government for approval. Same operator-sets-the-final-number logic underneath.
So three numbers stack: a revenue cap (regulator), per-product ceiling tariffs (regulator), and actual prices (operator, beneath the ceilings). The operator has pricing freedom only in the gap between the ceiling and zero.
The pricing formula is straight out of utility regulation
Here is the part overseas counsel should recognise immediately. The maximum permitted revenue is built on a “compensate cost, reasonable profit” principle (补偿成本、合理盈利) with an explicit formula (Articles 6–9):
Permitted revenue = operating cost + permitted profit + tax （准许收入 = 经营成本 + 准许利润 + 税金）
Each term is defined:
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Operating cost (经营成本, Article 7) is the reasonable expenditure net of government subsidies, fixed through a cost investigation (成本调查). It expressly includes (1) authorized-operation platform build and O&M; (2) data transmission, aggregation, storage and governance; (3) human resources; (4) the cost of obtaining the public data resources themselves; and (5) period expenses.
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Permitted profit (准许利润, Article 8) = operating cost × permitted profit rate. And the permitted profit rate is capped at:
the average yield of 10-year treasury bonds in the year before the cost investigation, plus no more than 6 percentage points.
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Tax (税金, Article 9) means taxes other than VAT — corporate income tax, urban maintenance and construction tax, and the education surcharge.
This is cost-of-service, rate-of-return regulation — the same toolkit China uses to price regulated natural monopolies such as gas-pipeline transmission and water (准许成本加合理收益, “permitted cost plus reasonable return,” with the return benchmarked to government-bond yields). The novelty is the subject matter: Guangdong has imported utility tariff methodology into the data-element market. For a foreign investor sizing a public-data operating venture in Guangdong, the practical consequence is that the upside is analytically capped — return on the regulated asset base is bounded at roughly the long-bond yield plus six points, not by what the market will bear.
How the ceiling translates into actual charges is left flexible (Article 10): tariffs may be levied by product quantity, number of service calls, service duration, or data-call volume, taking into account the data, compute, and storage consumed across different application scenarios. That metering flexibility matters for API-style data products, where “per call” or “per volume” is the natural unit.
Resets, true-ups, and a ±10% band
Because the data industry moves fast, the Measures build in periodic re-baselining rather than a fixed tariff:
- Periodic assessment (Article 12). The DRC and data authority reassess the maximum permitted revenue on a cycle of no more than three years, and may assess early if investment or cost changes materially. Crucially, over-recovery is clawed back: revenue earned above the permitted ceiling in one cycle is deducted when setting the next cycle’s cap (with large over-recoveries smoothed across cycles). This is a classic regulatory true-up — the operator cannot keep windfall revenue.
- Annual adjustment band (Article 13). Within a cycle, if actual revenue deviates from the permitted ceiling by 10% or less, the data authority guides the operator to adjust its specific charges; if the deviation exceeds 10%, the data authority adjusts the ceiling tariff itself.
- Reporting and cost separation (Articles 14–15). The data authority reports the operator’s prior-year results to the DRC by the end of March; the operator must run an independent price-management system and separately account for authorized-operation costs and revenue. For a multi-line business, that mandatory ring-fencing of the regulated activity is itself a compliance obligation — regulated public-data revenue cannot be commingled with the firm’s other books.
- Transparency and enforcement (Articles 16–17). The operator must clearly mark prices (明码标价) and publish its catalogue and tariffs on its portal. Supervision is split three ways: the DRC guides price-management practice, the data authority supervises the authorized-operation activity, and the market-regulation authority (市场监管, the SAMR line) polices price conduct — failure to follow the government-guided price, price fraud, and failure to clearly mark prices.
Two carve-outs worth flagging
- Public-governance and public-welfare data stays “conditionally free.” Article 18 keeps public-data products and services used for public governance and public-welfare purposes on a conditional free-of-charge basis (有条件无偿使用), per the data authority’s requirements. The service fee covers market-facing products, not the government’s own use or public-interest distribution. The same article also clarifies that revenue-sharing from the public data resources and from the operating platform is outside the scope of the operation service fee — i.e. the fee regulation does not reach the upstream revenue-distribution arrangements between the government and the operator.
- Public utilities get a parallel track. Where a public-utility enterprise (公用企业) conducts authorized operation, its sectoral authority sets the ceilings and handles pricing by reference to these Measures (Article 19) — a recognition that utilities (power, water, transport) sit on large public-data holdings and are already inside sector-specific price regulation.
Why this matters beyond Guangdong
- The price question is now being answered. Through 2024–25 the public-data story was about getting authorized and getting registered. With the national 65号 price-formation notice and Guangdong’s implementation, the regime is moving to what operators can charge — and the answer is a regulated, capped return, not market pricing. Expect Beijing, Zhejiang, Shanghai, and other early movers to issue parallel measures; Guangdong is a template to read now.
- Model the asset like a regulated utility, not a SaaS business. Any overseas party evaluating a Guangdong public-data operating role should build the financial model around permitted revenue = cost + (cost × capped return) + tax, with a three-year reset and over-recovery clawback. The return ceiling — long-bond yield + ≤6 points on the cost base — is the number that governs the investment case.
- Cost-base definition is where the value is contested. Because profit is a markup on operating cost, the cost investigation is the decisive regulatory event. What counts as a legitimate cost of “obtaining the public data resources,” of platform build, and of data governance will determine the permitted revenue. That is the proceeding to staff and document carefully.
- Ring-fencing is mandatory. The independent price-management system and separate accounting (Article 15) mean the regulated public-data line must be carved out of a diversified firm’s accounts from day one — not reconstructed at assessment time.
This is continuous with DCC’s broader public-data coverage — the authorized-operation processing-and-trading guide, the franchise/concession framing, and the reminder that authorized operation is not a liability shield — but it adds the missing economic layer. China is not only deciding who may operate public data and how; with Guangdong, it is now deciding what they may earn — and doing it with the price-control playbook used for utilities.
— Primary text: 政策｜广东出台公共数据授权运营价格管理办法（附全文）, 数据行者X WeChat Official Account. Full text (Chinese). Official interpretation: 《广东省公共数据资源授权运营价格管理办法》解读 (source: Guangdong DRC), reposted by 砖济咨询. Interpretation (Chinese). Issued 12 May 2026 by the Guangdong DRC and the Guangdong Provincial Administration of Government Services and Data; effective on issuance, five-year term.
Not legal advice. The above is DCC’s structural analysis and translation of a provincial pricing rule and its official interpretation. Article numbers refer to the Measures as reposted in full by 数据行者X.