The Evolving Landscape of Data Governance: A Global Perspective
China is building data exchanges, exporting governance via Digital Silk Road, and treating data as a national asset — not a privacy right.
The Chinese Approach to Data Governance
Since late 2025, Beijing has pursued an "AI-plus" initiative, focusing on aggressive AI adoption across industries with data at its core. The National Data Administration, established in 2023, has organized three national data work conferences and designated seven provinces as Digital Economy Innovation Development Pilot Zones.
China’s data governance framework is structured around:
- Cybersecurity Law
- Data Security Law
- Personal Information Protection Law
- Plus one administrative regulation: Regulation on Network Data Security Management, implemented through four specific rules.
This "3+1=4" structure establishes a layered regime for cross-border data flows, where the identity of the data processor, data type, and scale of transfers determine export mechanisms (security assessment, standard contracts, or personal information protection certification).
A Different Model from Europe
Unlike the European Union (EU) which treats data as a privacy right under the GDPR, and the United States that views it as a corporate asset, China considers data a factor of production and a national economic resource. This distinction leads to a fundamentally different data governance framework. While Brussels focuses on individual rights and transparency, Beijing prioritizes state sovereignty and national security.
The Global Impact
China’s model offers something the EU cannot: the physical infrastructure (roads, cables, data centers) necessary for a data economy to thrive. The country building this infrastructure is likely to set the global standard for data governance.
The EU AI Act, while significant, operates within a democratic legal framework, focusing on individual rights and transparency, while China’s approach places state control over privacy interests.