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Source-verified comparison

Automotive Data Rules: 2021 Provisions and the 2026 Export Security Guideline

2021 Automotive Data Security Provisions (Trial) and the complementary 2026 Automotive Cross-Border Data Transfer Security Guideline

Previous version2021-08-16
Current version2026-02-03
Legal statuseffective
Effective dateSee source

What changed

Material differences at a glance

The 2026 guideline does not repeal or replace the 2021 trial provisions. It operationalizes the national data-export framework for automotive scenarios by setting out route selection, exemptions, important-data identification, filing steps and security controls.

  • The 2021 provisions establish baseline automotive-data processing and export duties; the 2026 guideline adds an operational export workflow.
  • The 2026 guideline aligns automotive exports with security assessment, standard contract and certification routes.
  • The 2026 guideline adds nine stated exemption scenarios and scenario-based important-data identification.

Source comparison

5 reviewed change records
clarified

Legal relationship

Previous rule summary
The 2021 trial provisions establish baseline rules for automotive data processing and important-data cross-border transfers.
Compared rule summary
The 2026 guideline implements those baseline duties within the current national cross-border data transfer framework; it does not replace the 2021 provisions.

Practical impact: Compliance programs should apply both documents together.

The 2026 issuance announcement expressly cites the 2021 provisions.

added

Transfer-route selection

Previous rule summary
The 2021 provisions focus on the security-assessment requirement for important-data cross-border transfers and annual reporting.
Compared rule summary
The 2026 guideline identifies conditions for security assessment, standard contract and personal-information protection certification for cross-border transfers.

Practical impact: Automotive exporters gain a sector-specific route-selection sequence.

2026 guideline, general section and cross-border transfer process.

added

Exemptions

Previous rule summary
The 2021 provisions do not provide the 2026 guideline's nine-scenario export exemption framework.
Compared rule summary
The 2026 guideline states nine circumstances exempt from the three named export mechanisms, subject to their conditions.

Practical impact: Teams should test exemption conditions before initiating a transfer mechanism.

Official MIIT Q&A describes nine categories.

clarified

Important-data identification

Previous rule summary
The 2021 provisions define automotive important data at a baseline level.
Compared rule summary
The 2026 guideline provides scenario-based identification across R&D, manufacturing, driving automation, software updates and connected operations.

Practical impact: Data inventories should map category, item and description to the sector-specific identification rules.

Official MIIT Q&A.

clarified

Security controls

Previous rule summary
The 2021 provisions establish processing and security-management duties.
Compared rule summary
The 2026 guideline organizes export safeguards around management systems, technical protection, logs and incident response.

Practical impact: Export controls should be evidenced across governance, technical, logging and response workstreams.

Official MIIT Q&A.

Official sources

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