China’s cybersecurity laws are stricter than ever in 2025. To comply, businesses must follow key regulations like the Cybersecurity Law (CSL), Data Security Law (DSL), and Personal Information Protection Law (PIPL). Here’s a quick compliance checklist:
- Verify User Identity: Use mobile numbers or government IDs.
- Store Data Locally: All Chinese user data must stay on servers in China.
- Log Activities: Keep user activity logs for at least 60 days.
- Secure Data: Encrypt data at rest (AES-256) and in transit (TLS 1.3+).
- Perform Audits: Regular security checks and annual audits are mandatory.
- Manage Updates: OTA updates must be encrypted, logged, and user-approved.
Failing to meet these standards can result in fines up to ¥50 million (~$7.5 million) or 5% of annual revenue. Use tools like Capgo for encrypted updates and compliance tracking.
| Key Regulation | Effective Date | Impact |
|---|---|---|
| Network Data Security Management Regulation | Jan 1, 2025 | Tougher data compliance rules |
| CSL Amendments | Mar 28, 2025 | Higher penalties, stricter enforcement |
Stay compliant by securing user data, maintaining proper documentation, and following the latest updates in China’s cybersecurity framework.
Main Cybersecurity Laws and Regulations
China Cybersecurity Law (CSL)
The China Cybersecurity Law (CSL) lays out fundamental requirements for maintaining network security. These include real-name registration, implementing strong security measures, conducting regular assessments, and promptly reporting incidents. Recent amendments, set to take effect in March 2025, introduce stricter penalties for violations to align with evolving data protection standards [1].
Personal Information Protection Law (PIPL)
The Personal Information Protection Law (PIPL) enforces strict guidelines for managing user data, emphasizing transparency and security. Key provisions include:
| Requirement | Details | Implementation |
|---|---|---|
| User Consent | Obtain explicit permission for data collection and usage | Already in effect |
| Cross-border Transfers | Conduct security reviews and secure government approval for data exports | Within 60 days of collection |
| Data Protection | Apply technical safeguards to secure personal data | Ongoing monitoring |
PIPL also mandates that app developers adopt clear and open data-handling practices while maintaining detailed records of user consent. Violations can lead to operational suspensions and fines of up to ¥50 million (approximately $7.5 million) [2]. These rules form the backbone for the technical measures outlined in the Data Security Management Rules.
Data Security Management Rules
Starting January 1, 2025, the Network Data Security Management Regulation introduces a comprehensive framework for managing data-related risks. The regulation emphasizes:
- Risk Assessments: Evaluate data sensitivity, processing volumes, and potential national security impacts.
- Technical Safeguards: Classify data, implement access controls, and encrypt sensitive information.
- Incident Response: Maintain robust documentation and technical measures to address security incidents.
These updates aim to strengthen enforcement and tackle emerging cybersecurity challenges [1].
For app developers working on updates and security patches, utilizing secure update platforms can simplify compliance with these regulations. For instance, Capgo (https://capgo.app) offers end-to-end encryption and real-time update management, which is particularly valuable in a market with over 4 million mobile apps and the largest base of mobile Internet users worldwide [4].
Data Privacy Requirements
User Identity Verification
Before activating user accounts, implement real-name verification using either mobile phone numbers or government-issued IDs. Ensure the true identities are recorded and encrypted, while allowing users to display public aliases. Additionally, log user activities as required by regulations [4]. To streamline this process, consider integrating with authorized local verification services like those provided by China Mobile and China Unicom [4].
It’s equally important to ensure all stored data complies with local hosting regulations.
Data Storage Requirements
All data from Chinese users must be stored on servers located within mainland China, following the Network Data Security Management Regulation, which takes effect on January 1, 2025 [1]. If data needs to be transferred abroad, it must first undergo a government security review or obtain explicit user consent [3].
To meet these requirements, collaborate with authorized Chinese cloud providers like Alibaba Cloud or Tencent Cloud. This ensures that user data stays within the designated geographic boundaries.
Once storage requirements are met, focus on implementing the necessary security measures outlined below.
Required Security Standards
The cybersecurity framework for 2025 emphasizes using robust encryption protocols to safeguard user data [1][3]. Key measures include:
| Security Measure | Technical Specification | Purpose |
|---|---|---|
| Data at Rest | AES-256 encryption | Protect stored data |
| Data in Transit | TLS 1.3 or higher | Secure network communications |
For developers managing updates, platforms like Capgo offer built-in end-to-end encryption that aligns with these security requirements.
Regular audits and testing are crucial to ensure all security measures remain effective and up to date [1].
Cybersecurity and Data Protection in China Compliance, Challenges and Tips
Technical Security Requirements
China’s cybersecurity regulations require organizations to implement detailed technical security measures to stay compliant. In March 2025, the Cyberspace Administration of China (CAC) introduced amendments to the Cybersecurity Law (CSL) that outline these requirements, translating legal obligations into actionable practices [1].
Security Scanning Schedule
Mobile applications must undergo monthly security checks using CAC-approved scanning tools [1]. These assessments focus on various aspects of app security:
| Security Aspect | Assessment Frequency | Documentation Required |
|---|---|---|
| Vulnerability Assessment | Monthly | Scan reports with remediation timelines |
| Code Security Review | Monthly | Source code analysis results |
| Third-party Component Check | Monthly | Dependency audit reports |
All scan reports must be stored and made available for annual regulatory audits. Additionally, authorities may request immediate access to these results during inspections [1][5].
User Permission Controls
Role-based access control (RBAC) is a non-negotiable requirement for mobile applications operating in China [1]. Developers are expected to:
- Set up precise permission levels based on user roles.
- Maintain detailed logs of access activities.
- Regularly review and update permission settings to ensure they remain appropriate.
For developers handling app updates, platforms like Capgo offer built-in tools to manage user roles and permissions efficiently while enabling quick deployment of security patches.
Security Incident Response
Organizations must notify the CAC of any security incidents within 12 hours of detection. This notification should include an initial assessment and details of containment measures [1][5].
A comprehensive incident response plan should cover:
- Detection and containment of the issue.
- Investigation and communication strategies.
- User notifications, when necessary.
Post-incident, document the root cause, remediation actions, and any updates to security protocols. A detailed report must then be submitted to the regulatory authorities.
“The latest amendments to the CSL have increased enforcement and raised penalty amounts to align with other major data protection laws in China, such as the PIPL and DSL”, states the Cyberspace Administration of China in their March 2025 guidance [1].
Regular security drills and staff training sessions are also required, with all related documentation kept on hand for regulatory inspections [1][2].
App Store Requirements
When it comes to publishing apps in China, meeting technical standards is just the beginning. Developers must also adhere to regulations set by the Cyberspace Administration of China (CAC) and the Ministry of Industry and Information Technology (MIIT) [1].
MIIT Registration Process
To register with the MIIT, developers need to prepare the following:
- A business license or organization certificate, along with an authorization letter
- A detailed description of the app’s functionality and data collection practices
- Documentation of network security assessments
- A personal information protection impact assessment
The standard review process typically takes 7–10 business days. However, foreign developers often face extended processing times - up to 2–3 months - due to the requirement of working through a local entity. These steps build upon earlier technical safeguards to ensure both data security and user privacy.
Security Testing Requirements
In addition to registration, apps must undergo mandatory security testing. The Network Data Security Management Regulation, set to take effect on January 1, 2025, outlines specific testing protocols based on app categories [3]:
-
Finance and Healthcare Apps
These apps require penetration testing and source code reviews conducted by CAC-approved organizations. Developers must also retain security documentation for three years. -
Social and Education Apps
Testing focuses on vulnerability assessments and compliance with data protection standards. Additionally, user activity logs must be maintained for at least 60 days [4]. -
General Applications
These apps are subject to basic checks, including encryption standards and data handling practices. They must also provide user identity verification through approved methods.
SDK Compliance Check
Developers need to maintain a detailed inventory of all SDKs used in their apps, including:
- SDK name, version, and provider
- Data access permissions and storage locations
- Security certificates
- Compliance with the Personal Information Protection Law (PIPL) and Data Security Law (DSL) [2]
For apps relying on cloud-based updates, platforms like Capgo provide tools for version control and patch deployment that align with Chinese cybersecurity standards.
To enforce compliance, the CAC has implemented a whistleblowing system. Non-compliance can lead to app removal and hefty penalties [4].
Update Management
In China, managing updates goes beyond technical tweaks - it’s about meeting stringent cybersecurity regulations that are constantly evolving [1].
OTA Update Requirements
Over-the-air (OTA) updates in China must adhere to a strict set of security and compliance rules [1]. Here’s what’s required:
- End-to-end encryption: Update packages must be encrypted during transmission and include digital signatures to confirm their authenticity [1].
- User verification: Updates can only proceed after explicit user consent, often verified through mobile number validation [4].
- Data localization: The infrastructure used to deliver updates for Chinese users must be physically located within China [2].
- Documentation: Keep detailed logs of updates, including information about user consent, access records, and security evaluations, for at least 60 days [3].
For critical security patches, the Cyberspace Administration of China (CAC) enforces swift action. Companies must issue vulnerability notifications immediately and expedite the deployment of fixes [1].
These requirements are closely tied to a well-organized version management system.
Version Management
Under the Network Data Security Management Regulation, which takes effect in January 2025, companies must implement robust version control processes. Here’s what that entails:
| Requirement | Duration | Purpose |
|---|---|---|
| Version History | Minimum 60 days | For security audits and investigations |
| Change Logs | Comprehensive | Document all updates and modifications |
| Security Assessments | Per update | Ensure compliance with regulations |
| User Distribution Tracking | Ongoing | Monitor how updates are adopted |
Rollback capabilities are essential, allowing companies to revert to previous versions quickly. These older versions must also be preserved for at least 60 days [3].
When using third-party services for version management, companies must ensure the following: registration with Chinese authorities, deployment of localized infrastructure, clear documentation of responsibilities, and compliance with data localization laws [1].
For platforms managing sensitive data, updates that alter data collection methods or access permissions require extra layers of testing and validation to maintain regulatory compliance [4].
Tools like Capgo (https://capgo.app) provide live update solutions that include encryption, seamless CI/CD integration, and detailed version control features.
Failing to comply with these regulations can lead to severe consequences, such as fines reaching up to 5% of the previous year’s revenue and removal from Chinese app stores [2].
Compliance Documentation
China’s cybersecurity framework places a strong emphasis on thorough documentation. With the March 2025 amendments, the requirements have become stricter, and the penalties for non-compliance have increased significantly [1].
Required Annual Audits
Apps are required to undergo detailed security audits to ensure they align with the Personal Information Protection Law (PIPL), Data Security Law (DSL), and the latest Cybersecurity Law (CSL) amendments [1][2]. Here’s an overview of typical audit schedules and document retention requirements:
| Audit Type | Frequency | Documentation Period |
|---|---|---|
| Standard Apps | Annual | 5 years |
| Critical Infrastructure / High Data Volume Apps | Semi-annual | 5 years |
These audits must include documentation such as security assessment reports, data processing records, user consent mechanisms, privacy policy acknowledgments, and incident response plans.
Data Flow Documentation
When transferring data across borders, organizations must provide detailed documentation of data flow maps, conduct security assessments, secure explicit user consent, and implement risk mitigation strategies. These records must be retained for at least three years after the termination of the transfer relationship [2].
Log Storage Rules
The Network Data Security Management Regulation outlines specific requirements for log retention [3]. These include:
-
System Activity Logs
- User registration details
- Login timestamps with IP addresses
- Feature usage patterns
- Content publishing activities
-
Financial Transaction Logs
- Must be stored for at least three years
- Include full transaction details
- Ensure tamper-proof storage
-
Administrative Access Logs
- Record system administrator activities
- Track data access events
- Log modifications and export/download activities
-
General Logs
- Retention requirement: minimum of 60 days [4]
Failure to maintain these logs can lead to penalties of up to 5% of annual revenue [1]. Additionally, automated update services must document all update-related activities to demonstrate compliance.
Proper documentation is the foundation for all other compliance measures, including staff training and incident response planning.
Compliance Training and Violations
Violation Response Plans
The March 2025 amendments to the CSL emphasize the importance of having detailed protocols in place to address violations [1]. A solid response plan typically involves the following key phases:
| Response Phase | Required Actions |
|---|---|
| Initial Detection | - Suspend affected services - Document incident details - Notify the internal compliance team |
| Authority Notification | - Report to the Cyberspace Administration of China (CAC) - Submit a preliminary assessment - Outline a remediation plan |
| Rectification | - Implement technical fixes - Update security protocols - Document all changes |
| Post-Incident | - Submit a final report - Conduct a follow-up audit - Update training materials |
The CAC has also introduced a public whistle-blowing system, which underscores the need for quick, well-documented responses [4]. To support these efforts, organizations should pair their response plans with thorough staff training programs to ensure compliance at every level.
Staff Training Requirements
Starting January 2025, the Network Data Security Management Regulation mandates formal training programs to align with technical and documentation standards [3]. These training programs are essential to staying compliant with the latest regulatory requirements.
Mandatory Annual Training Topics
- Principles of data privacy and proper handling procedures
- Updates on the CSL and Personal Information Protection Law (PIPL)
- Secure coding techniques
- Incident response protocols
- User identity verification processes
Documentation Practices
- Keep records of training attendance, assessments, and material updates
- Ensure training documentation is always up-to-date
- Track acknowledgments of regulatory updates
Organizations must also provide additional training whenever significant regulatory changes occur, such as the CSL amendments set for March 28, 2025 [1].
Practical Steps for Effective Training
- Assign a dedicated compliance officer to monitor and implement regulatory updates
- Subscribe to regulatory update services and participate in industry workshops
- Conduct regular internal compliance assessments
- Leverage compliance management software to streamline processes
Frequent, well-structured training not only ensures adherence to regulations but also helps mitigate compliance risks effectively.
Conclusion: Compliance Checklist Summary
This checklist highlights the essential areas for meeting compliance with China’s regulatory framework, which is shaped by its three core laws. Strict adherence, supported by the right tools, is necessary to align with the latest amendments.
| Compliance Area | Requirements | Tools |
|---|---|---|
| Data Privacy | - Verify user identity through mobile numbers - Maintain activity logs for at least 60 days - Ensure secure data storage | - Identity verification systems - Secure logging platforms - Local storage solutions |
| Security Standards | - Perform regular vulnerability assessments - Establish incident response protocols - Use end-to-end encryption | - Security scanning tools - Response management systems - Encryption frameworks |
| Update Management | - Deploy security patches promptly - Maintain version control - Ensure app store compliance | - OTA update solutions - Version management tools - Compliance checkers |
The Network Data Security Management Regulation, effective January 1, 2025, enforces stricter compliance measures [3]. To meet these requirements while ensuring smooth app updates, developers can rely on tools like Capgo, which provides end-to-end encrypted OTA updates tailored to the Chinese market.
Here are a few key steps to stay compliant:
- Keep track of regulatory changes and update internal protocols as needed.
- Document all security measures and data-handling practices thoroughly.
- Conduct regular security assessments and train staff on compliance protocols.
- Set up strong incident response systems to address potential threats.
Failure to comply can lead to penalties ranging from formal warnings to the removal of apps from Chinese app stores [4].
FAQs
::: faq
What steps should developers follow to ensure their mobile apps comply with China’s cybersecurity regulations in 2025?
To align with China’s cybersecurity regulations set for 2025, developers need to prioritize compliance with the latest legal standards and ensure their apps meet stringent data protection requirements. Here are some key areas to focus on:
- Secure data storage and transmission: Use encryption to safeguard sensitive user data, both when it’s stored and during transmission, to block unauthorized access.
- Data localization: If required, keep user data within China to comply with local data storage laws.
- User consent and transparency: Clearly explain how user data is collected, used, and shared. Make sure to get explicit consent from users when necessary.
- Regular security assessments: Perform routine audits and vulnerability scans to uncover and resolve potential security issues.
Capgo supports developers in achieving compliance by providing end-to-end encryption and real-time updates for Capacitor apps. This ensures that updates, whether for fixes or new features, are deployed instantly without waiting for app store approvals - keeping your app secure and compliant with ease. :::
::: faq
What steps can developers take to securely store and transmit user data while complying with China’s cybersecurity regulations?
To align with China’s cybersecurity regulations, developers must focus on the secure storage and transmission of user data. Here’s how this can be achieved:
- Use strong encryption standards to secure sensitive data both when stored and during transmission.
- Employ secure communication protocols like HTTPS and TLS to safeguard data while it’s being transferred.
- Continuously monitor and upgrade security measures to counter emerging vulnerabilities and threats.
- Comply with China’s Personal Information Protection Law (PIPL) and Cybersecurity Law, including requirements to store data on servers located within China if necessary.
Platforms such as Capgo can simplify compliance efforts by offering real-time updates. This allows apps to stay secure and current without the need for app store approvals. Additionally, Capgo’s end-to-end encryption strengthens data protection, making it easier to meet regulatory demands. :::
::: faq
What are the risks of not complying with China’s cybersecurity regulations, and how can businesses address them?
Failing to follow China’s cybersecurity regulations can result in serious repercussions, such as hefty fines, removal of apps from app stores, data breaches, and even legal action. Beyond these, non-compliance can severely harm a company’s reputation, making it challenging to maintain a foothold in the Chinese market.
To reduce these risks, businesses must ensure their apps align with all regulatory standards. This includes adhering to data localization rules, obtaining user consent for data collection, and conducting thorough security assessments. Tools like Capgo can simplify the process by helping developers roll out updates and fixes efficiently, ensuring compliance without disrupting app functionality. Keeping up-to-date with regulatory changes and addressing them proactively is essential for avoiding penalties and achieving long-term success in China. :::
