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.