China consults on the Provisions on the Establishment of Personal Information Protection Supervision Committees by Significant Network Platforms
The Cyberspace Administration of China (CAC) released the Provisions on the Establishment of Personal Information Protection Supervision Committees by Significant Network Platforms (Consultation Draft) (Draft Provisions) on 12 September 2025. The Draft Provisions, as an implementation measure, if finalised on this basis, provide detailed guidance for significant network platforms (the Significant Platforms) on how to establish an independent mechanism to supervise their performance in safeguarding personal information.
Among others, the following key aspects of the Draft Provisions are worth noting:
- Application scope. Network platform service providers with complex operations or services and either more than 50 million registered users or 10 million monthly active users whose data-processing activities materially impact national security or the economy will likely be considered as Significant Platforms. Notably, the Draft Provisions provides that a list of Significant Platforms will be separately formulated and published.
- Responsibilities of the Committee. A Significant Platform is required to establish a committee supervising its personal information protection, specifically in the following aspects, among others: (1) developing personal information protection compliance systems; (2) revising personal information protection rules for the platforms or products; (3) implementing rectifications required by the regulators ; (4) handling personal information security incidents; and (5) ensuring compliance with requirements on cross-border personal information transfer. The Committee is empowered to issue opinions and urge the Significant Platform to implement such opinions within ten days. If the relevant Significant Platform fails to address the Committee's opinions to its satisfactory, the Committee may further report to CAC's local office.
- Composition of the Committee. Each Committee must comprise a minimum of seven members. Its exact size shall calibrate to the scale and user base of the relevant Significant Platform, with at least two-thirds being independent outsiders whose independence is verified on appointment and maintained throughout their tenure.
- Supervision of the Committee. The Committee is required to function under platform-drafted rules issued for at least 15 days of public consultation before finalisation. In addition, the approved rules and committee members' information are required to then be publicly disclosed. The approved rules shall be filed with the local CAC, to which an annual report of the Committee's supervisory work must also be submitted.
Platforms that may be recognised as Significant Platforms are advisable to closely follow the Draft Provisions' formulation process and, during the consultation window, submit feedback reflecting their specific business models and practices.