What is the primary objective of **PIPL**?

**PIPL's primary objective is to protect natural persons' personal information rights while regulating processing activities to promote reasonable data use.** Enacted August 20, 2021, and effective November 1, 2021, its 74 articles establish principles of lawfulness, necessity, minimization, transparency, accuracy, integrity, confidentiality, and accountability (Article 5), defining personal information as recorded data related to identified or identifiable individuals, excluding anonymized data (Article 4).

Who is legally or professionally required to comply with **PIPL**?

**PIPL requires compliance from all personal information handlers—domestic or foreign—processing data of natural persons in China.** This includes extraterritorial entities providing products/services to or analyzing behaviors of Chinese individuals (Article 3). Handlers processing PI of over 1 million individuals must appoint a **Personal Information Protection Officer (PIPO)** and report to authorities; foreign handlers must designate a China-based representative (Articles 51-53).

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

**PIPL does not mandate external audits or third-party certification for general compliance but requires them for specific scenarios.** Handlers of PI from over 10 million individuals must conduct compliance audits every two years; high-risk cross-border transfers (>1M individuals or >10K **sensitive personal information (SPI)**) need **CAC security assessments** or certification (Articles 55, 2024 Provisions). Internal **Personal Information Protection Impact Assessments (PIPIAs)** are mandatory for SPI, automated decision-making, and transfers (Article 55).

How often should an assessment for **PIPL** be performed?

**PIPL requires regular internal assessments, with PIPIAs before high-risk processing and compliance audits every two years for large-scale handlers.** Records must be retained at least three years (GB/T 39335-2020). Handlers of >10M individuals' PI undergo biennial audits; ongoing monitoring via security education, incident response, and risk reviews is mandated (Article 51). Regulators may demand third-party audits post-breach.

What are the consequences of non-compliance with **PIPL**?

**Non-compliance with PIPL incurs administrative fines up to **RMB 50 million** or **5% of prior-year global revenue**, whichever is higher, plus personal liability up to RMB 1 million for executives.** Grave violations trigger business suspension, license revocation, and criminal penalties (Article 66). Examples include Didi's RMB 1.2 billion fine (2022); enforcement by **CAC** involves inspections, orders, and public shaming.

Can **PIPL** be mapped to other international frameworks?

**PIPL shares principles like data minimization and accountability with international frameworks but differs in lacking a broad legitimate interests basis and emphasizing consent and localization.** Its extraterritorial scope, SPI rules (biometrics, health, minors <14), and cross-border mechanisms (SCCs, assessments) align conceptually with GDPR yet require distinct mappings for consent granularity, ADM prohibitions, and CAC filings.

What is the first step to begin implementing **PIPL**?

**The first step for PIPL implementation is a comprehensive gap analysis and data mapping.** Inventory all PI flows, classify general vs. **SPI**, identify volumes, purposes, legal bases, and transfers to produce a processing register and risk heatmap (Phase 1 framework). Secure executive sponsorship and appoint a program lead to prioritize high-risk areas like SPI and cross-border flows.

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 ensuring security controls match the potential harm from system compromise to national security, social order, and public interests.** It classifies systems into five levels (1-5) based on impact severity, mandating commensurate technical, management, physical, and personnel controls via standards like GB/T 22239-2019, with enforcement by Public Security Bureaus (PSBs).

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

**All network operators in mainland China must comply with MLPS 2.0 under Article 21 of the 2017 Cybersecurity Law.** This includes domestic enterprises, foreign-invested entities, cloud providers, and operators of IT, IoT, big data, and industrial systems; critical sectors like finance and energy often classify at Level 3+.

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

**Yes, MLPS 2.0 requires external security reviews by licensed Chinese firms for Level 2+ systems, targeting a minimum score of 75/100.** PSB approval follows submission of reports; Level 3+ mandates periodic evaluations (annual for Level 3).

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

**Assessments under MLPS 2.0 must occur biennially for Level 2, annually for Level 3, semi-annually for Level 4, and as mandated for Level 5.** Re-evaluations are also required after major changes; Level 1 relies on self-inspection.

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

**Non-compliance with MLPS 2.0 risks fines up to 100,000 yuan, operational suspensions, business license denials, and intensified PSB inspections.** Severe cases link to broader sanctions under the Cybersecurity Law, as seen in fines exceeding RMB 200 million for data failures.

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

**Yes, MLPS 2.0 control domains (e.g., governance, physical, technical) map to ISO 27001 Annex A and NIST CSF categories.** Organizations leverage existing ISMS for gap analysis, though MLPS adds prescriptive grading, PSB oversight, and data localization unique to China.

PIPL vs MLPS 2.0 (Multi-Level Protection Scheme)

Q: What is the first step to begin implementing **PIPL**?

**The first step for PIPL implementation is a comprehensive gap analysis and data mapping.** Inventory all PI flows, classify general vs. **SPI**, identify volumes, purposes, legal bases, and transfers to produce a processing register and risk heatmap (Phase 1 framework). Secure executive sponsorship and appoint a program lead to prioritize high-risk areas like SPI and cross-border flows.

Q: 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 ensuring security controls match the potential harm from system compromise to national security, social order, and public interests.** It classifies systems into five levels (1-5) based on impact severity, mandating commensurate technical, management, physical, and personnel controls via standards like GB/T 22239-2019, with enforcement by Public Security Bureaus (PSBs).

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

**All network operators in mainland China must comply with MLPS 2.0 under Article 21 of the 2017 Cybersecurity Law.** This includes domestic enterprises, foreign-invested entities, cloud providers, and operators of IT, IoT, big data, and industrial systems; critical sectors like finance and energy often classify at Level 3+.

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

**Yes, MLPS 2.0 requires external security reviews by licensed Chinese firms for Level 2+ systems, targeting a minimum score of 75/100.** PSB approval follows submission of reports; Level 3+ mandates periodic evaluations (annual for Level 3).

Standards Comparison

PIPL

Mandatory

2021

China's comprehensive regulation for personal information protection

MLPS 2.0 (Multi-Level Protection Scheme)

Mandatory

N/A

China's mandatory graded cybersecurity protection regime

Quick Verdict

PIPL protects personal data privacy for China operations with consent and transfer rules, while MLPS 2.0 mandates graded cybersecurity for networks via classification and audits. Companies adopt both for legal compliance, risk mitigation, and market access in China.

Data Privacy

PIPL

Personal Information Protection Law (PIPL)

Cost

€€€€

Complexity

Medium

Implementation Time

6-12 months

Key Features

Extraterritorial scope targeting China individuals
Explicit separate consent for sensitive PI
Cross-border transfers with security assessments
Fines up to 5% annual revenue
Mandatory impact assessments for high-risk processing

Standard

MLPS 2.0 (Multi-Level Protection Scheme)

Multi-Level Protection Scheme 2.0

Cost

€€€€

Complexity

High

Implementation Time

12-18 months

Key Features

Five-level impact-based system classification
Mandatory third-party audits for Level 2+
PSB enforcement and on-site inspections
Extended controls for cloud, IoT, big data
Governance and personnel security requirements

Detailed Analysis

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

PIPL Details

What It Is

Personal Information Protection Law (PIPL) is China's comprehensive national regulation enacted August 20, 2021, effective November 1, 2021. It governs collection, processing, storage, transfer, and deletion of personal information (PI) for natural persons in China. Modeled partly on GDPR but consent-centric, PIPL uses a risk-based approach emphasizing individual rights, data minimization, and national security.

Key Components

Eight chapters, 74 articles covering processing rules, cross-border transfers, individual rights, handler obligations.
Core principles: lawfulness, necessity, minimization, transparency, accountability.
Sensitive PI (biometrics, health, minors <14) requires explicit consent.
Compliance via PIPIAs, no broad legitimate interests basis; enforcement by CAC with fines to 5% revenue.

Why Organizations Use It

PIPL compliance mitigates severe penalties, operational disruptions, reputational harm. It enables market access, builds consumer trust, enhances resilience. Strategic for multinationals serving China, intersecting CSL/DSL.

Implementation Overview

Phased: gap analysis, data mapping, policies, controls, audits (6-12 months). Applies to all handling China PI, extraterritorially; appoint China reps, DPOs for large handlers. No certification but CAC reviews/transfers.

MLPS 2.0 (Multi-Level Protection Scheme) Details

What It Is

MLPS 2.0 (Multi-Level Protection Scheme 2.0) is China's legally mandated cybersecurity framework under the 2017 Cybersecurity Law. It requires network operators to classify systems into five protection levels based on potential harm to national security, social order, and public interests, implementing graded technical, organizational, and governance controls.

Key Components

Core domains: physical security, network protection, data security, access control, monitoring, and governance.
Standards like GB/T 22239-2019, GB/T 25070-2019 define baselines, extended for cloud, IoT, big data.
Five levels with escalating requirements; Levels 2+ need third-party audits (75/100 score) and PSB approval.

Why Organizations Use It

Mandatory for all China-based networks to avoid fines, suspensions.
Enhances resilience, supports market access, aligns with data laws.
Builds regulator trust, reduces breach risks.

Implementation Overview

Phased: classify, gap analysis, remediate, audit, file with PSBs.
Applies to all sizes in China; recurring re-evaluations.
External audits mandatory for Levels 2+.

Key Differences

Aspect	PIPL	MLPS 2.0 (Multi-Level Protection Scheme)
Scope	Personal data processing, privacy rights	Graded cybersecurity for networks/systems
Industry	All handling Chinese personal data	All network operators in China
Nature	Mandatory privacy law, CAC enforcement	Mandatory cybersecurity scheme, PSB enforcement
Testing	DPIAs, compliance audits for large handlers	Third-party assessments, periodic re-evaluations
Penalties	Up to 5% revenue or RMB 50M fines	Fines, operations suspension, inspections