CSL (Cyber Security Law of China)
China's regulation for network security and data localization
ISO 22301
International standard for business continuity management systems
Quick Verdict
CSL mandates cybersecurity and data localization for China operations, enforced by fines up to 5% revenue. ISO 22301 offers voluntary BCMS certification for global resilience via BIA and testing. Companies adopt CSL for legal compliance in China; ISO 22301 for disruption recovery and trust.
CSL (Cyber Security Law of China)
Cybersecurity Law of the People's Republic of China
Key Features
- Mandates data localization for CII and important data in Mainland China
- Requires security assessments for cross-border data transfers
- Assigns cybersecurity responsibilities to senior executives
- Imposes mandatory network security testing and real-time monitoring
- Enforces incident reporting within 24 hours to authorities
ISO 22301
ISO 22301:2019 Business continuity management systems β Requirements
Key Features
- PDCA cycle for continual BCMS improvement
- Business Impact Analysis prioritizing critical functions
- Risk assessment and treatment planning
- Leadership commitment with policy and roles
- Operational testing exercises and audits
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
CSL (Cyber Security Law of China) Details
What It Is
The Cybersecurity Law of the Peopleβs Republic of China (CSL), enacted on June 1, 2017, is a national statutory regulation comprising 69 articles. It establishes a comprehensive framework governing network operators, critical information infrastructure (CII) operators, and data processors within Chinese jurisdiction. Its primary purpose is to protect network security, ensure data sovereignty, and enforce cybersecurity governance. CSL adopts a pillar-based approach focusing on mandatory safeguards, localization, and accountability.
Key Components
- **Three core pillarsNetwork Security (safeguards, testing, monitoring), Data Localization & Personal Information Protection (storage in Mainland China, transfer assessments), Cybersecurity Governance (executive duties, incident reporting).
- Applies broadly to any entity handling Chinese data.
- Built on risk-based classification of data and systems (CII, important data).
- Compliance via self-assessments, government evaluations, and audits like Security Protection Capability Test (SPCT).
Why Organizations Use It
CSL is legally binding, with fines up to 5% of annual revenue for non-compliance, operational disruptions, and reputational harm. It mitigates risks like data breaches and regulatory penalties while enabling market access, consumer trust, operational efficiency through modern architectures, and innovation via local R&D. Foreign firms gain competitive edges in China's market.
Implementation Overview
Follows a **phased GRC frameworkstakeholder alignment, gap analysis, architectural redesign (e.g., local clouds, Zero-Trust), governance setup, testing/certification. Targets organizations with Chinese users across sizes/industries. Requires ongoing monitoring, training, and adaptation to intersecting laws like PIPL/DSL.
ISO 22301 Details
What It Is
ISO 22301:2019 is the international standard titled Security and resilience β Business continuity management systems β Requirements. It specifies requirements for a Business Continuity Management System (BCMS) to protect against, reduce likelihood of, and recover from disruptions. Employing a PDCA (Plan-Do-Check-Act) cycle and Annex SL high-level structure, it uses a risk-based, flexible approach without prescriptive controls.
Key Components
- 10 clauses (4-10 auditable): context of organization, leadership, planning (BIA, RA), support, operation, performance evaluation, improvement.
- Core principles: Business Impact Analysis (BIA), risk assessment, testing exercises, continual enhancement.
- Certification model: 3-year validity with annual surveillance audits via accredited bodies.
Why Organizations Use It
Drives resilience, minimizes downtime/financial losses, ensures compliance (e.g., NIS Directive, NIST), boosts stakeholder trust/reputation, lowers insurance premiums, provides procurement advantages. Certified firms gain competitive edges amid cyber/pandemic threats.
Implementation Overview
Gap analysis, BIA/RA, documentation, training, testing, internal/external audits. Suits all sizes/sectors globally. Two-stage certification (6-8 weeks); tools enable 60 days to 6 months.
Key Differences
| Aspect | CSL (Cyber Security Law of China) | ISO 22301 |
|---|---|---|
| Scope | Network security, data localization, governance | Business continuity management system |
| Industry | China-based network operators, CII, all sizes | All sectors, global, all sizes |
| Nature | Mandatory national law, fines/enforcement | Voluntary certification standard |
| Testing | Penetration tests, SPCT, government evaluation | BIA, exercises, internal/external audits |
| Penalties | Fines up to 5% revenue, license revocation | Loss of certification, no legal fines |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CSL (Cyber Security Law of China) and ISO 22301
CSL (Cyber Security Law of China) FAQ
ISO 22301 FAQ
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