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China PI Compliance Audit Measures

In force China · In force May 1, 2025 · no upcoming deadlines

Deadlines

DateWhat happens
May 1, 2025PI compliance audit measures take effect17 months ago

Summaries for reference, not legal advice. Check the official text.

What it does

Implements PIPL Arts. 54 and 64: PI processors must audit their own PIPL compliance regularly, and regulators can order an audit by a professional firm when they find high risk or an incident. Processors of PI of more than 10 million people must audit at least once every two years.

Who it applies to
All personal information processors in China; mandatory biennial audits for processors handling PI of more than 10 million individuals. The related CAC Q&A ties the DPO requirement to processors handling PI of 1 million+ individuals.
Penalties
Penalties are imposed under the PIPL (up to RMB 50 million or 5% of prior-year turnover for serious violations).
Enforced by
CAC and departments with PI protection duties
Official name
Administrative Measures for Personal Information Protection Compliance Audits (CAC Order No. 18)
Citation
CAC Order No. 18
Topics
privacy
Verified 2026-09-22 cac.gov.cn
Research notes

The measures fix no calendar date for the first biennial audit. The 1-million DPO threshold comes from the CAC announcement and law-firm summaries, not re-read in the official text here.

Related

Questions about China PI Compliance Audit Measures
What are the China PI Compliance Audit Measures compliance deadlines?
May 1, 2025: PI compliance audit measures take effect.
When does China PI Compliance Audit Measures take effect?
China PI Compliance Audit Measures took effect on May 1, 2025.
Who does China PI Compliance Audit Measures apply to?
All personal information processors in China; mandatory biennial audits for processors handling PI of more than 10 million individuals. The related CAC Q&A ties the DPO requirement to processors handling PI of 1 million+ individuals.
What are the penalties under China PI Compliance Audit Measures?
Penalties are imposed under the PIPL (up to RMB 50 million or 5% of prior-year turnover for serious violations).

When the rules change: new data, privacy and AI laws and deadlines, the next morning.