Filed under cac
Every brief tagged "cac".
- § 01 · PERSONAL-INFORMATION
China Finishes the Other End of PIPL: The Draft Provisions for Large Personal Information Handlers, Read Against Order No. 25
On 7 August 2026 the CAC published the Provisions on Personal Information Protection for Large Personal Information Handlers (Draft for Comment), consolidating its September 2025 supervision-committee draft and its November 2025 large-network-platform draft into one 50-article instrument, with comments due 7 September 2026. DCC has translated the full text and reads it against CAC/MPS Order No. 25, the small-handler regime published sixteen days earlier — because the pair is the story. Three shifts matter most. The subject changes from 'large network platform' to 'large personal information handler,' and the old registered-user and monthly-active-user tests give way to a three-factor test starting at 10 million data subjects, which reaches banks, insurers, carriers, hospitals and automakers that never thought of themselves as platforms. Designation is declared rather than automatic: a qualifying handler must self-declare through its provincial CAC and the national CAC publishes a public list, which puts the burden of self-identification on the company. And the obligations that follow are structural rather than procedural — absolute domestic storage under Article 13, a nationality requirement for data center controllers under Article 14, a protection officer drawn from management with a direct reporting line to the provincial CAC, and a supervision committee that is not a committee of the board. DCC sets out the full comparison table, the designation trap, and what the newly visible middle band means for foreign-invested subsidiaries.
- § 02 · CYBERSECURITY-REVIEW
China Opens a Cybersecurity Review of Palo Alto Networks: The Micron Playbook, Now Pointed at Firewalls
On 6 August 2026 the Cybersecurity Review Office announced a cybersecurity review of Palo Alto Networks (派拓公司) products sold in China, citing the National Security Law, the Cybersecurity Law and the Cybersecurity Review Measures. DCC reads the announcement against the Measures themselves. The review is an Article 16 own-motion proceeding initiated by the working mechanism and cleared by the Central Cyberspace Affairs Commission — not the Article 5 pathway where a CIIO declares a procurement — so there is no applicant, no declared transaction, and the Article 11/14 clocks apply only by analogy. Article 21 puts cybersecurity equipment and cloud computing services squarely in scope; Article 10 supplies the risk factors that a cloud-synchronized firewall estate maps onto almost line by line. The operative question for overseas counsel is not what happens now — nothing does — but what a failed outcome would mean: CIIOs must stop procuring, and CSL Article 37/67 as amended in 2025 exposes a CIIO that keeps using un-passed products to a fine of 1× to 10× the procurement amount plus RMB 10,000–100,000 personally. Non-designated companies acquire no legal obligation at all. Based on commentary from 数据何规, checked against the official announcement and the Micron precedent.
- § 03 · PERSONAL-INFORMATION
China Writes PIPL a Small-Business Exit Ramp: The Simplified Measures for Small Personal Information Handlers
On 22 July 2026 the CAC and the Ministry of Public Security jointly issued Order No. 25, the Provisions on Simplified Personal Information Protection Measures for Small Personal Information Handlers, effective 1 September 2026. It is the first instrument to make PIPL's obligations formally proportionate: a handler processing the personal information of fewer than 100,000 people gets a three-item processing-rules template it can satisfy with a posted notice, notice discharged through those published rules alone, consent inferred from voluntary provision of necessary information, compliance audit cut to once every five years — or waived entirely if certified — and a one-page impact assessment. Article 8 lets a handler operating solely through a network platform drop its own rules, notice, audit and assessment altogether, riding on the platform's. Article 10 extends the cross-border exemption architecture to small handlers, with important data carved out. Articles 18 and 19 make no-penalty and mitigated-penalty outcomes mandatory rather than discretionary. DCC reads it for overseas counsel whose Chinese counterparties, franchisees, merchants and portfolio companies sit under the 100,000-person line — and explains why the threshold, not the relief, is the thing to watch.
- § 04 · RISK-ASSESSMENT
From Principle to Running System: How the Network Data Security Risk Assessment Measures Operationalize the Data Security Law
On June 18, 2026 the CAC, MIIT and the Ministry of Public Security jointly issued the Measures for Network Data Security Risk Assessment as Order No. 24, effective August 20, 2026. The 25-article rule adds no new substantive duty; it turns the Data Security Law's open-ended 'conduct risk assessment' obligation into an executable, verifiable, trigger-able governance system. DCC reads it as a three-tier standing model plus an event-driven escalation layer: important-data handlers must assess every year (general-data handlers are encouraged to every three), retain the report for three years and submit it within 20 working days; sectoral competent authorities run annual inspection plans filed by end-January; the national cyberspace administration consolidates and cross-shares reports with telecom, public-security and state-security departments; and where a high-risk finding or a breach of important data or large-scale personal information appears, regulators can compel assessment by a certified institution and order the operator to cease processing important data. The four institutional increments over the DSL: an annual mandatory action, networked multi-department supervision, a three-track assessment structure, and dynamic event-triggered oversight.
- § 05 · ENFORCEMENT
CAC Names 30 Apps and Mini-Programs for PI Violations — Nearly Half for Ineffective Account Cancellation
On June 11, 2026 the Office of the Central Cyberspace Affairs Commission published a notification naming 30 apps and mini-programs for personal-information collection and use violations, found in testing organized under the 2026 CAC + MIIT + MPS joint special campaign. The violations fall into four categories — undisclosed PI collection rules (7 apps), frequent demands for non-essential permissions (4), incomplete SDK disclosure (5), and, the dominant category at 14 of 30, failure to provide an effective account-cancellation function. DCC reads the notification as the CAC tier of the same campaign whose MIIT testing tier we covered in the Batch 56 brief: a broader perimeter that expressly includes mini-programs, a 15-working-day rectify-and-report deadline, and a clear signal that exit rights — account cancellation and deletion — are a 2026 testing priority.