China: Shanghai Municipal Internet Information Office issued Pilot Free Trade Zone and Lingang New Area Data Outbound Management List (Negative List)

On 8 February 2025, the Shanghai Municipal Internet Information Office, in collaboration with several municipal bodies, officially adopted the Negative List management measures for data export under the China (Shanghai) Pilot Free Trade Zone (FTZ) and Lingang New Area. This framework aims to facilitate cross-border data transfers in alignment with international standards, whilst maintaining data security oversight and compliance. The Negative List is applicable to the finance, shipping, and commerce sectors, delineating significant data and personal information categories, as well as six data export scenarios. The Negative List eliminates the requirement for pre-approval, empowering businesses to self-assess their compliance and report data export activities within a 15-working-day timeframe. Certain low-risk data transfers, including international trade, HR management, and emergency transfers, are exempt from security assessments. The Shanghai government has announced its intention to expand the scope of industry coverage, refine compliance measures, and strengthen regulatory oversight with a view to supporting digital trade and institutional openness.