CN
China | Regulatory Framework Status: in force
Effective: 2026-01-09
moderate

CAC Q&A (Jan 2026) on personal information protection policy and compliance (incl. AI-related processing)

Personal Information Protection Policy and Regulations Q&A (January 2026)

I. Regulatory Summary

Relevant to legal/advisory practitioners supporting AI deployments that involve personal data (particularly biometrics): the CAC’s interpretive Q&A signals supervisory expectations around impact assessments, record retention, and governance obligations.

II. Full Description

The CAC published a January 2026 policy-and-regulations Q&A to support personal information processors. The Q&A includes AI-adjacent compliance clarifications such as conducting and documenting personal information protection impact assessments for facial recognition processing and governance/reporting expectations for responsible persons under the personal information protection framework.

III. Scope & Application

Official CAC Q&A providing compliance clarifications on personal information protection topics, including requirements relevant to AI-enabled processing (e.g., facial recognition impact assessments, record-keeping, and responsible person reporting).

IV. Policy Impact Assessment

Relevant to legal/advisory practitioners supporting AI deployments that involve personal data (particularly biometrics): the CAC’s interpretive Q&A signals supervisory expectations around impact assessments, record retention, and governance obligations.

Primary Focus: data protection guidance (AI-adjacent)