Key takeaways

• On June 1, 2017, China’s anticipated and controversial Network Security Law officially came into force. The Law will impose substantial obligations on businesses operating in China and potentially affect multinationals’ IT infrastructure and ability to transfer data abroad.
• Both the law and the implementing regulations that accompany it remain vague, both in terms of what the obligations are and how they apply to various kinds of entities. Foreign business groups and the chambers of commerce which represent them in China continue to push for greater clarity.
• However, the effectiveness of the implementing regulation relating to data localization and cross-border transfer of data has been delayed for 18 months.