What is the primary objective of **MLPS 2.0 (Multi-Level Protection Scheme)**?

**The primary objective of MLPS 2.0 is to establish a graded cybersecurity protection system for all network operators in China, ensuring security controls match the potential impact of system compromise on national security, social order, public interests, and rights of individuals and organizations.** It operationalizes Article 21 of the 2017 Cybersecurity Law through five protection levels (Level 1 self-protection to Level 5 controlled protection), with common baseline controls plus extended requirements for cloud, IoT, big data, and industrial systems. This prevents interference, protects CIA triad, and mandates monitoring, logging, and incident response scaled by harm severity.

Who is legally or professionally required to comply with **MLPS 2.0 (Multi-Level Protection Scheme)**?

**All network operators in mainland China are legally required to comply with MLPS 2.0, including domestic enterprises, foreign-invested companies, cloud providers, and operators of IT, OT, IoT, or big data systems.** Defined broadly under the Cybersecurity Law, this covers any entity owning, managing, or providing network services. Critical infrastructure in energy, finance, transport, and healthcare often grades at Level 3+, with enforcement by Public Security Bureaus (PSBs) via inspections and filings.

Does **MLPS 2.0 (Multi-Level Protection Scheme)** require an external audit or third-party certification?

**Yes, MLPS 2.0 requires external audits by licensed third-party agencies for systems at Level 2 and above, with PSB approval of results.** Level 1 needs only self-filing; Level 2 mandates expert review and biennial evaluations; Level 3 requires annual assessments scoring at least 75/100 across technical, management, and physical controls; Levels 4-5 face semi-annual or ministry-directed reviews. Audits cover architecture, logs, policies, and personnel.

How often should an assessment for **MLPS 2.0 (Multi-Level Protection Scheme)** be performed?

**Assessments under MLPS 2.0 must be performed biennially for Level 2, annually for Level 3, semi-annually for Level 4, and as mandated for Level 5, plus upon major system changes.** Self-assessments apply to all levels; external third-party evaluations are required for Level 2+. PSBs enforce via inspections, tying compliance to license renewals.

What are the consequences of non-compliance with **MLPS 2.0 (Multi-Level Protection Scheme)**?

**Non-compliance with MLPS 2.0 results in administrative fines up to RMB 100,000+, operational suspensions, system shutdowns, and intensified PSB inspections.** Severe cases link to Cybersecurity Law penalties, including blacklisting, license revocation, and criminal liability for executives. Enforcement examples include RMB 50,000 fines post-hacks and RMB 223 million for banks failing controls and reporting.

Can **MLPS 2.0 (Multi-Level Protection Scheme)** be mapped to other international frameworks?

**Yes, MLPS 2.0 control domains map closely to ISO 27001 Annex A and NIST CSF categories, enabling integrated compliance.** Governance, physical, network, data, and operations align with ISO organizational/people/physical/technological controls; risk-based grading parallels NIST tiers. Organizations overlay MLPS-specific elements like PSB filings and data localization atop global ISMS.

What is the first step to begin implementing **MLPS 2.0 (Multi-Level Protection Scheme)**?

**The first step for MLPS 2.0 implementation is conducting a self-assessment to inventory systems and classify each into one of five protection levels based on compromise impact.** Evaluate affected objects (individuals to national security) and harm severity using GB/T 22239-2019 guidance, followed by filing with local PSBs within 30 days for Level 2+.

What is the primary objective of **ISO 27018**?

**ISO 27018 provides a code of practice for protecting **PII** in public clouds acting as **PII processors**.** It extends **ISO 27001** and **ISO 27002** with ~25–30 privacy-specific controls addressing cloud risks like multi-tenancy, subprocessor transparency, consent, purpose limitation, data minimization, breach notification, and restrictions on secondary PII use (e.g., no marketing without consent). The 2025 edition aligns with **ISO 27002:2022**, enabling CSPs to demonstrate auditable processor obligations.

Who is legally or professionally required to comply with **ISO 27018**?

**ISO 27018 targets public cloud service providers (**CSPs**) acting as **PII processors** for customers.** It applies to hyperscalers, regional platforms, and sector-specific clouds (e.g., health, finance) processing PII via multi-tenant environments. Controllers use it for vendor due diligence, but it excludes controller-specific duties and private clouds. Adoption is driven by procurement demands, regulatory alignment (e.g., GDPR Article 28), and market differentiation, not legal mandates.

Does **ISO 27018** require an external audit or third-party certification?

**ISO 27018 requires assessment via external audits as an extension of **ISO 27001** certification, not standalone.** Accredited bodies (under **ISO/IEC 17021** and **ISO/IEC 27006**) evaluate controls in the **Statement of Applicability** during **ISO 27001** Stage 1/2 audits. Certificates reference both standards, valid for 3 years with annual surveillance; no independent **ISO 27018** certificate exists.

How often should an assessment for **ISO 27018** be performed?

**ISO 27018 assessments occur annually via surveillance audits, with full recertification every 3 years alongside **ISO 27001**.** Integrated into the **ISMS**, ongoing internal reviews monitor control effectiveness amid cloud changes (e.g., new services, subprocessors). Gap analyses support continual improvement.

What are the consequences of non-compliance with **ISO 27018**?

**Non-compliance with **ISO 27018** risks lost procurement, regulatory scrutiny, and eroded trust, as it signals weak **PII** processor controls.** No direct fines apply (voluntary code), but misalignment exposes CSPs to GDPR/HIPAA breaches, cyber insurance denials, contract losses, and reputational damage from incidents lacking transparency or notification.

Can **ISO 27018** be mapped to other international frameworks?

**Yes, **ISO 27018** maps directly to frameworks like **ISO 27001**, **ISO 27002**, **ISO 27017** (cloud security), and **ISO 27701** (PIMS).** Controls align with GDPR Article 28 processor duties, OECD principles, and **ISO/IEC 29100** on consent, transparency, and data subject rights, enabling unified **ISMS** implementation.

What is the first step to begin implementing **ISO 27018**?

**Conduct a gap analysis against **ISO 27018** controls within your **ISO 27001 ISMS** as the first step.** Review policies, **Statement of Applicability**, contracts, subprocessors, and PII lifecycle (e.g., logging, deletion) via stakeholder interviews, prioritizing transparency, breach notification, and data rights support.

MLPS 2.0 (Multi-Level Protection Scheme) vs ISO 27018

Standards Comparison

MLPS 2.0 (Multi-Level Protection Scheme)

Mandatory

N/A

China's mandatory graded cybersecurity for networks

ISO 27018

Voluntary

2019

Code of practice for PII protection in public clouds

Quick Verdict

MLPS 2.0 mandates graded cybersecurity for all China networks via police enforcement, while ISO 27018 voluntarily extends ISO 27001 for cloud PII processors. Companies adopt MLPS for legal compliance in China; ISO 27018 for global cloud privacy trust.

Standard

MLPS 2.0 (Multi-Level Protection Scheme)

Multi-Level Protection Scheme 2.0 (GB/T 22239-2019)

Cost

€€€€

Complexity

Medium

Implementation Time

12-18 months

Key Features

Five graded levels based on impact severity
Mandatory for all China network operators
Technical, management, physical controls baseline
Third-party audits for Level 2+ systems
Extensions for cloud, IoT, big data

Cloud Privacy

ISO 27018

ISO/IEC 27018:2025 Code of practice for PII in public clouds

Cost

€€€

Complexity

Medium

Implementation Time

6-12 months

Key Features

Privacy controls for public cloud PII processors
Subprocessor and location transparency requirements
Prohibits PII use for marketing without consent
Customer breach notification obligations
Data minimization and secure deletion mandates

Detailed Analysis

A comprehensive look at the specific requirements, scope, and impact of each standard.

MLPS 2.0 (Multi-Level Protection Scheme) Details

What It Is

MLPS 2.0 (Multi-Level Protection Scheme) is China's mandatory cybersecurity regulation operationalizing the 2017 Cybersecurity Law's Article 21. It is a graded protection framework classifying networks into five levels based on breach impact to national security, social order, and public interests. Scope covers all network operators, including modern tech like cloud, IoT.

Key Components

Domains: physical, network, host, data security, operations, governance.
Baseline controls plus level-specific extensions.
Standards: GB/T 22239-2019 (requirements), GB/T 25070-2019 (technical), GB/T 28448-2019 (evaluation).
Compliance via self-classification, third-party audits (Level 2+), PSB filing.

Why Organizations Use It

Legal mandate enforced by PSBs with fines, inspections. Enhances resilience, supports CII/data laws. Builds trust, enables market access.

Implementation Overview

Phased: inventory/classify, gap analysis, remediate, audit/file, ongoing re-evals. Applies to all China operators; high for critical sectors. Mandatory audits scale by level.

ISO 27018 Details

What It Is

ISO/IEC 27018:2025 is a code of practice extending ISO/IEC 27001 and ISO/IEC 27002 for protecting personally identifiable information (PII) in public clouds where providers act as PII processors. It addresses cloud-specific privacy risks like multi-tenancy and cross-border flows via risk-based controls within an ISMS.

Key Components

~25–30 privacy-specific controls on consent, purpose limitation, minimization, transparency, accountability.
Aligned with ISO 27001 Annex A themes: Organizational, People, Physical, Technological.
Built on ISO 29100 principles; assessed during ISO 27001 audits, not standalone.

Why Organizations Use It

Builds trust, speeds procurement, aligns with GDPR/ HIPAA processor duties.
Mitigates risks, aids insurance, differentiates CSPs in competitive markets.

Implementation Overview

Gap analysis, ISMS integration, SoA updates, policy/contract/tech enhancements.
For CSPs globally, all sizes; third-party audits via ISO 27001 with annual surveillance.