PUBLISHED MARKET GUIDE
Shanghai Expands Outbound Data Transfer Negative List Citywide
Shanghai has expanded its negative list management system for outbound data transfers from the free trade zone and Lin-gang Special Area to the entire city.
Shanghai has expanded its negative list management system for outbound data transfers to the entire city, following the initial negative list released in February 2025 for the China (Shanghai) Pilot Free Trade Zone and the Lin-gang Special Area. The new list, issued under the national comprehensive pilot program for expanding opening-up in the service sector, provides clearer guidance for companies handling cross-border data flows.
Independently written English guidance based on cited public sources. Every public guide is human reviewed; it is not an official translation of the source publisher.
What is a negative list for outbound data transfers?
China supports the lawful, orderly, and free flow of data across borders. Under relevant laws and regulations, companies handling outbound data transfers may need to follow one of three main compliance procedures: applying for a security assessment, signing a standard contract for the outbound transfer of personal information, or obtaining personal information protection certification.
These procedures do not apply to all types of data. They primarily concern important data and certain volumes of personal information. General data that does not involve these categories may flow freely across borders in accordance with the law.
In simple terms, the negative list identifies the types of data that must undergo these compliance procedures. Data that falls outside the negative list may be transferred overseas without applying for security assessments, signing standard contracts, or obtaining certification.
What sectors does Shanghai's negative list cover?
Shanghai's negative list covers four sectors: finance, shipping, trade and commerce, and meteorology. It includes nine specific scenarios and 29 data categories, though the complete details are not provided in the available text.
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