INTA Data Committee

Jurisdictions / China

China

Asia-Pacific · Law stated as at Aug 2026

Overview — from the Part II reportFixed reference content

China treats data as a strategic asset within its digital economy and protects it through a layered regime of copyright, the Anti-Unfair Competition Law (AUCL), contract provisions of the Civil Code, and an expanding body of data security and personal information law. Under Article 15 of the Copyright Law, databases showing originality in selection or arrangement may be protected as collective works — as in Shanghai Hantao v. Aibang Juxin, involving Dianping.com's restaurant reviews — though stringent evidentiary standards make copyright actions relatively uncommon in practice.

The AUCL is the primary vehicle for data disputes, protecting trade secrets defined as non-public technical or commercial information with commercial value and confidentiality measures; in Qucheng v. Wu Tianci, customer data including contact information, transaction records, and pricing qualified for protection. Criminal liability attaches where secrets are obtained by theft, fraud, or other illicit means. China has no sui generis database right, but the 'Data Twenty Articles' policy and pilot programs in Shanghai, Zhejiang, and Shenzhen are testing data registration and property-rights models.

Personal information and data security rest on three pillars — the PIPL, the Cybersecurity Law, and the Data Security Law — and the 2023 Interim Measures for Generative Artificial Intelligence Services require that training datasets be lawful and that outputs meet standards of safety, accuracy, and fairness. In Taobao v. Anhui Meijing (2018), the court distinguished raw behavioral data, which holds minimal standalone value, from processed data products, in which network operators may claim proprietary interests — a distinction critical to AI systems built on derived datasets.

Key takeaways

  • The Anti-Unfair Competition Law, not copyright, is the workhorse for protecting databases and customer data in China.
  • Courts recognize proprietary interests in processed data products (Taobao v. Anhui Meijing), while raw behavioral data carries minimal standalone value.
  • High evidentiary burdens make trade secret and copyright enforcement challenging, particularly for foreign entities.
  • Generative AI providers must ensure training data is lawful under the 2023 Interim Measures, alongside PIPL, CSL, and DSL compliance.
  • The 'Data Twenty Articles' and regional pilot programs signal an emerging data property-rights registration system worth monitoring.

Primary legal instruments

Copyright Law, Art. 15 (collective works)Anti-Unfair Competition Law (AUCL)Civil Code (Arts. 464–465, 1034)PIPL (2021) / Data Security Law (2021)Interim Measures for Generative AI Services (2023)Taobao v. Anhui Meijing (2018)

AI-assisted summary of the report, editorially reviewed before publication · AI transparency

Protection mechanisms

Report-derived analysis per mechanism. The report text is fixed; committee members with contributor access can revise the rating (with an audit trail) and add notes below each block.

Recent Developments

Live updates contributed by committee members and the AI research bot — separate from the fixed report content above.

Cyberspace Administration of China Releases 2026 Report on New E-commerce Development

29 Aug 2026GuidanceFinalCAC#Trade Secrets#Contracts#Unfair CompetitionAI-generated

The Cyberspace Administration of China (CAC) has officially released its "2026 Report on New E-commerce Development." This comprehensive report likely analyzes trends, challenges, and policy recommendations for the rapidly evolving e-commerce sector. Given e-commerce's inherent reliance on vast amounts of data, the report is expected to touch upon data utilization, data security, and the economic value of data within this industry.

CAC 网信发布 / 政策法规

China Outlines Strategic Development Plan for Emerging Industries, Emphasizing AI and Data-Driven Innovation

26 Aug 2026GuidanceEnactedState Council#AI-Specific RulesAI-generated

China's State Council has unveiled its strategic plan for the next five years, focusing on the accelerated development of emerging and future industries. This includes significant investment in AI, 6G, and industrial internet technologies, with a strong emphasis on leveraging these for scientific research and new application scenarios. The plan highlights the importance of structured data utilization and innovation in driving industrial transformation.

State Council policy portal

State Council Meeting Directs Accelerated Construction of Next-Generation Communication Networks and Data Security

22 Aug 2026GuidanceEnactedState Council#Trade Secrets#AI-Specific RulesAI-generated

A State Council executive meeting has mandated the accelerated development of next-generation communication networks, including 5G, 6G, and industrial internet. The directive emphasizes fostering high-value application scenarios like smart cities and intelligent manufacturing, which rely heavily on data. Crucially, it also calls for strengthening critical network infrastructure and data security protection, underscoring the importance of safeguarding data assets.

State Council policy portal

Central Cyberspace Affairs Commission Issues Action Plan for High-Quality Development of Cyberspace Enterprises

21 Aug 2026Rule changeApprovedCAC#AI-Specific Rules#Trade Secrets#Sui GenerisAI-generated

The Central Cyberspace Affairs Commission (CAC) has released a five-year action plan to promote the high-quality development of cyberspace information enterprises. This plan outlines strategic objectives and measures for the sector from 2026 to 2030, aiming to foster innovation and enhance the overall competitiveness of China's digital economy. It is expected to guide policy and regulatory efforts impacting data-driven businesses and technological advancements.

CAC 网信发布 / 政策法规

National Data Administration Initiates Pilot Program for International Data Cooperation in Ten Regions

21 Aug 2026Rule changeApprovedNational Data Administration#Sui Generis#ContractsAI-generated

The National Data Administration (NDA) has announced the launch of its first batch of international data cooperation pilot projects across ten locations in China. This initiative aims to explore new models for cross-border data flows and data governance, fostering international collaboration in the data field. The program is expected to inform future policies on data exchange and the global circulation of data assets.

Regulator Clarifies Implementation of Network Data Security Risk Assessment Measures

20 Aug 2026GuidanceCAC#Trade Secrets#Sui GenerisAI-generated

The Central Cyberspace Affairs Commission (CAC) published a Q&A document to clarify various aspects concerning the implementation of its Measures for Network Data Security Risk Assessment. This guidance aims to assist organizations in understanding their obligations and the procedures for conducting data security risk assessments, ensuring compliance with national data protection standards. It provides practical insights into managing data-related risks and safeguarding sensitive information.

CAC 网信发布 / 政策法规

Supreme People's Court 2025 Typical IP Cases include data-scraping unfair competition ruling with tiered data protection

20 Apr 2026AI-generated

On 20 April 2026 the Supreme People's Court released its Typical Intellectual Property Cases of 2025, including a case where competitors bypassed an e-commerce platform's anti-scraping controls to mass-extract product data. The court held that circumventing security measures to scrape data at scale constituted unfair competition, and articulated a tiered protection approach distinguishing public, conditionally disclosed, and non-public data. As SPC-endorsed typical cases, these rulings guide lower courts nationwide on the boundaries of lawful data competition.

China's National Data Administration issues draft national Guidelines for Data Property Registration (Trial)

3 Apr 2026AI-generated

On 3 April 2026 the National Data Administration published draft Guidelines for Data Property Registration (Trial) for public comment, with feedback due by 19 April 2026. The six-chapter, 42-article draft would create a nationwide registration framework recognizing three proprietary data rights — holding, use, and operation — building on the earlier Beijing, Shanghai and Shenzhen pilots. While registration does not create a new enforcement right, registered certificates can evidence data as an intangible corporate asset, supporting balance-sheet recognition and financing.

NDA pledges to accelerate building of China's data property rights registration system

12 Jan 2026AI-generated

State Council media reported on 12 January 2026 that the National Data Administration, at a symposium led by NDA head Liu Liehong, committed to accelerating construction of a national data property rights registration system to unlock the value of data. The NDA said it would adapt registration experience from other fields to data's unique characteristics, consulting bodies including the Beijing Internet Court on the supporting policy documents. This announcement set the policy direction that produced the April 2026 draft registration guidelines.