China has enacted a major revision of its Cybersecurity Law, effective January 1, 2026. The amendments mark the most significant shift since the law's original introduction in 2017 and materially change how companies must handle cyber incidents, regulatory reporting, and compliance exposure.
The updated framework places speed and accountability at the center of enforcement. Incident response is no longer measured in days. In several cases, regulators now expect disclosure within minutes of detection.
Incident reporting timelines shrink dramatically
The most immediate operational change is the new reporting requirement for cybersecurity incidents. Operators of critical information infrastructure, and in some cases general network operators, must notify authorities of significant incidents within extremely short windows.
Depending on severity, initial reporting is required within four hours, or as little as 60 minutes. These timelines are reinforced by the Administrative Measures for National Cybersecurity Incident Reporting, which came into force on November 1, 2025, and consolidate reporting rules under a single framework enforced by the Cyberspace Administration of China (CAC). Incidents are classified into four severity levels. "Relatively major" incidents include data breaches affecting more than one million individuals or financial losses exceeding RMB 5 million.
These must be reported within four hours of discovery, followed by a detailed assessment within 72 hours and a post-incident report within 30 days. At the highest level, "particularly serious" incidents must be reported within one hour. Authorities are then required to escalate the report to national regulators and the State Council within 30 minutes, compressing escalation timelines to an unprecedented degree.
Higher penalties and personal accountability
The amended law significantly increases penalties for non-compliance. Organizations found to be in serious violation can now face fines of up to RMB 10 million. Individuals directly responsible, including executives and security leadership, may be fined up to RMB 1 million.
Enforcement procedures have also changed. Regulators are no longer required to issue warnings or remediation orders before imposing penalties. This allows authorities to move directly to sanctions, reducing the time organizations have to correct deficiencies after an incident.
Supply chain risk is explicitly addressed as well. Operators of critical infrastructure may be penalized for using non-compliant products or services, with fines in some cases reaching up to ten times the procurement value. Vendor selection and third-party risk management now carry direct regulatory consequences.
Expanded reach beyond China's borders
The revised law broadens its extraterritorial scope. Earlier versions focused on foreign activities that directly harmed China's critical information infrastructure. The amended language extends jurisdiction to foreign conduct that endangers China's network security more broadly.
This expansion affects multinational organizations with indirect exposure, including cloud services, software dependencies, managed service providers, and manufacturing or logistics systems that intersect with China-connected networks. In severe cases, authorities are authorized to impose measures such as asset freezes or other sanctions. For global enterprises, compliance obligations can now arise from architectural and operational decisions made entirely outside China.
Artificial intelligence enters the legal framework
For the first time, artificial intelligence is explicitly referenced in the Cybersecurity Law. The amendments promote the use of AI to enhance cybersecurity management while simultaneously calling for stronger ethics oversight and safety governance.
The law does not yet define detailed AI compliance requirements. Those are expected to emerge through follow-up regulations or technical standards. The inclusion itself signals that cybersecurity compliance in China is expanding beyond traditional infrastructure security into algorithmic risk and system-level accountability.
Clear thresholds for severe incidents
The CAC's reporting measures also define what qualifies as a "particularly serious" incident. Examples include cyber incidents that disable government portals or major news platforms for more than 24 hours, or six hours in cases of complete system failure. Large-scale disruptions affecting essential services for more than half of a province's population, or impacting the daily lives of more than 10 million people, are also included.
Data breaches involving personal information of more than 100 million individuals or financial losses exceeding RMB 100 million fall into the same category. Once an incident is resolved, operators must submit a comprehensive report within 30 days covering root causes, response actions, impact, corrective measures, and lessons learned.
What organizations should be doing now
The practical impact of the amendments is immediate. Incident response plans that assume extended investigation periods no longer align with legal requirements. Security teams must be able to classify incidents, assess severity, and trigger regulatory notification almost immediately.
Decision-making authority may need to be delegated in advance, especially for multinational organizations operating across time zones. Evidence collection and documentation processes must function in parallel with response, not after containment. For companies connected to Chinese infrastructure through suppliers, software, or services, the amended law turns speed and documentation into enforceable legal obligations rather than best practices.
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