Standards Comparison

    PIPL

    Mandatory
    2021

    China's comprehensive law for personal information protection

    VS

    NERC CIP

    Mandatory
    2006

    Mandatory standards for BES cybersecurity and reliability

    Quick Verdict

    PIPL governs personal data protection for China-facing operations with strict consent and transfer rules, while NERC CIP mandates cyber/physical security for North American electric grid reliability. Companies adopt PIPL for market access; CIP for regulatory compliance and grid stability.

    Data Privacy

    PIPL

    Personal Information Protection Law (PIPL)

    Cost
    €€€€
    Complexity
    Medium
    Implementation Time
    6-12 months

    Key Features

    • Extraterritorial scope for foreign entities targeting China
    • Consent-first model without legitimate interests basis
    • Explicit separate consent for sensitive personal information
    • Tiered cross-border transfer mechanisms with thresholds
    • Penalties up to 5% of annual global revenue
    Critical Infrastructure Protection

    NERC CIP

    NERC Critical Infrastructure Protection Standards

    Cost
    €€€
    Complexity
    Medium
    Implementation Time
    18-24 months

    Key Features

    • Risk-based BES Cyber System impact categorization
    • Electronic/Physical Security Perimeter requirements
    • 35-day patch evaluation and monitoring cadences
    • Incident response and recovery plan testing
    • Configuration change and vulnerability management

    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 in 2021, effective November 1. It governs collection, processing, storage, transfer, and deletion of personal information with extraterritorial scope for entities targeting Chinese individuals. Adopting a risk-based, consent-centric approach, it protects individual rights while aligning with cybersecurity and data security laws.

    Key Components

    • 74 articles across eight chapters covering processing rules, cross-border transfers, individual rights, and enforcement.
    • Core principles: lawfulness, necessity, minimization, transparency, accountability.
    • Sensitive personal information (SPI) rules, seven legal bases (consent primary), data subject rights (access, deletion, portability).
    • Compliance via PIPIA assessments, no certification but CAC security reviews for transfers.

    Why Organizations Use It

    PIPL is mandatory for compliance, avoiding fines up to 5% annual revenue. It mitigates operational risks, enables market access in China, builds consumer trust, and supports strategic data flows.

    Implementation Overview

    Phased approach: gap analysis, data mapping, policy updates, controls, monitoring (6-12 months). Applies to all sizes handling Chinese data; multinationals need China representatives. Focus on high-risk sectors like tech, finance.

    NERC CIP Details

    What It Is

    NERC CIP (North American Electric Reliability Corporation Critical Infrastructure Protection) are mandatory reliability standards for cybersecurity and physical security of the Bulk Electric System (BES). They mitigate risks of misoperation or instability through a risk-based, tiered approach categorizing assets as High, Medium, or Low Impact.

    Key Components

    • Core standards: CIP-002 (scoping), CIP-003 (governance), CIP-004 (personnel), CIP-005/006 (perimeters), CIP-007 (systems security), CIP-008-010 (response/recovery/config), up to CIP-014 (supply chain/physical).
    • ~45 requirements across 14 standards.
    • Built on recurring cycles (15/35/90-day cadences).
    • Enforced via audits, penalties by NERC/FERC.

    Why Organizations Use It

    • Legal mandate for BES owners/operators.
    • Prevents fines, outages; enhances resilience.
    • Builds trust with regulators, stakeholders.
    • Drives efficiency in OT/IT security.

    Implementation Overview

    • Phased: scoping, controls, testing, audits.
    • Involves inventory, segmentation, training.
    • Applies to utilities in US/Canada/Mexico.
    • Annual audits, 3-year evidence retention. (178 words)

    Key Differences

    Scope

    PIPL
    Personal data protection, processing, transfers
    NERC CIP
    Cyber/physical security for electric grid BES

    Industry

    PIPL
    All sectors handling Chinese personal data
    NERC CIP
    Electric utilities, grid operators in North America

    Nature

    PIPL
    Mandatory national privacy law
    NERC CIP
    Mandatory reliability standards enforced by FERC

    Testing

    PIPL
    DPIAs for high-risk, CAC audits
    NERC CIP
    Annual audits, 15/35-day cadenced assessments

    Penalties

    PIPL
    Up to 5% revenue or RMB 50M fines
    NERC CIP
    Millions in FERC fines per violation

    Frequently Asked Questions

    Common questions about PIPL and NERC CIP

    PIPL FAQ

    NERC CIP FAQ

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