On March 22, 2024, the Cyberspace Administration of China (CAC) unveiled the current version of China’s rules governing outbound data transfers. International observers and Chinese legal academics viewed the 2024 rules, which replaced a cumbersome 2022 regime, as a significant move to ease cross-border business. For some companies and organizations, they brought relief from burdensome filing and review requirements before moving everyday data across borders, but some elements of the new regime left uncertainties.
In this essay, the authors take up these uncertainties through original analysis and a survey of Chinese expert opinion. The essay provides a snapshot of a constantly developing Chinese data governance regime that in 2024 reached a new stage.
