China: National Data Administration opened consultation on draft model contract for data intermediary services

On 18 April 2025, the National Data Administration of China opened a consultation, set to close on 18 May 2025, on a draft model contract for data intermediary services. This contract sets forth terms for third-party entities that facilitate data transactions, including obligations to remain neutral, requirements for record-keeping, duties of transparency towards transaction participants, and liability provisions in the event of contractual breaches or data-related incidents.