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New FTZ Data Policies, CBDT 2.0 Move Toward Greater Flexibility

Key Takeaways

  • China’s free trade zones are shifting toward a more flexible and unified approach to data transfers, with the Shanghai FTZ introducing its first batch of negative lists.
  • CAC has signaled a shift toward a more business-responsive approach to data governance, referred to as “CBDT 2.0.”
  • Despite progress, sector-specific inconsistencies and vague “important data” classifications continue to pose operational challenges, particularly in the healthcare and financial services industries.

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