A Close Reading of China’s New Cybersecurity Review Measures, in Effect Feb 15, 2022 | Dezan Shira & Associates

Several revisions in China’s updated Cybersecurity Review Measures, in effect from February 15, 2022, focus on risks associated with data processing activities and the data security risks arising from Chinese entities listing overseas. Under the new Measures, network platform companies with access to the personal information of more than one million users will need to apply for a cybersecurity review before listing abroad. A reading of the language of the new Measures has resulted in industry experts assuming that the geographical scope of “foreign listings” does not include Hong Kong. If this understanding is correct, the Measures could shift more Chinese companies towards Hong Kong IPOs to avoid potential reviews.

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