CHINA Trends and Developments Contributed by: Huihui Li, James Hu, Yingjie Kang, Sherry Xu, Bivio Yu and Lisa Zhao, Fangda Partners
actions and penalties are anticipated in the coming months, where: • the first phase targets six key issues, including the circulation of illegal AI products, the teaching and selling of such products, poor management of training materials, inadequate safety measures, failure to implement content labelling requirements and safety risks in critical areas; and • the second phase focuses on seven major issues, such as using AI to generate rumours, false infor - mation and pornographic content, impersonating others, engaging in online manipulation activities and infringing on the rights of minors. Important data protection The DSL formulates a national data classification regime and provides that the processing of important data is subject to more stringent rules. The RNDSM released in 2024 reiterates the rules on the identifica - tion and protection of important data under the DSL.
In 2024 and 2025, many sectoral and regional regula - tors are carrying out the campaign for important data identification in their sectors or regions. For example, the Ministry of Industry and Information Technology issued guidelines on the identification of important data in the industrial and telecommunication sectors and required companies to submit their categories of important data; and the Tianjin, Beijing, Shanghai, Hainan, Zhejiang, Guangxi, Jiangsu and Chongqing Pilot Free Trade Zones published the categories of important data in the respective regions. As data protection regulations become more defined, companies should monitor the progress of critical data identification across relevant sectors and regions and implement compliance measures promptly.
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