China: Interim Measures for the Administration of Compliance Data Reporting in Online Transactions
Published 10 April 2025
Sarah Xuan
On April 2, 2025, the State Administration for Market Regulation (“SAMR”) issued the Interim Measures for the Administration of Compliance Data Reporting in Online Transactions (“Measures”), and Measures will officially come into effect on April 25, 2025. This new regulation will establish a unified and clear legal framework for data reporting and supervision mechanisms within online trading platforms. At the same time, the Measures introduce a standardized data reporting mechanism, which improve regulatory capabilities through digitalization and intelligence, enabling precise regulation and post-event governance, and promoting the orderly and healthy development of the platform economy. In this article, we will analyze the main elements of the Measures and its impact on enterprises, and provide relevant recommendations.
I. Key Provisions Explained 1. Scope and Applicability (Articles 1–3) The Measures apply to online transaction platform operators within the territory of the People’s Republic of China, requiring them to report compliance data generated domestically to market supervision authorities. This includes traditional e-commerce platforms, social media platforms, live-streaming commerce providers, and others. According to the Measures, “Compliance data” refers to:1) Identity information of online business operators;2) Clues related to violations of law;3) Data required for enforcement assistance;4) Transaction data concerning specific goods or services.
2. Reporting Principles (Article 4) The Measures require adherence to the principles of balancing development and security, legality, and necessity. Emphasis is placed on:1) Protecting the legitimate rights of platform operators and consumers;2) Preventing excessive data collection and the disclosure of trade secrets and personal privacy;3) Avoiding interference with the normal operations of platforms and their users.
3. Regulatory Responsibilities (Articles 5–6) According to the Measures, the SAMR is responsible for national-level planning and oversight, while local market supervision departments manage data reporting and administration within their jurisdictions. The Measures encourage the use of automated systems and open data interfaces to improve efficiency and standardization in data submission.
4. Detailed Reporting Requirements (Articles 7–10) The Measures provides that enterprises must report the following to provincial-level regulators:1) Basic identity information of the platform and merchants;2) Special markings for merchants with annual transactions over RMB 100,000;3) Reports of violations by merchants within five working days of administrative action;4) Assistance in providing transaction-related data (payments, logistics, after-sales, etc.);5) Data on sales, volume, and prices of specified goods/services by time period or region.
5. Correction and Supplement Mechanisms (Articles 11–12) The Measures require, when submitted data is found to be inaccurate or incomplete, regulators may request corrections or supplementary submissions within five working days. Platforms may also proactively apply for corrections if errors are identified.
6. Data Use and Security (Articles 13–15) According to the Measures, regulators may use the reported data for lawful supervision, analytics, and service delivery purposes, but must not exceed their legal authority. Strict compliance with the Data Security Law, Cybersecurity Law, and Personal Information Protection Law is required to prevent abuse or unauthorized disclosure.
7. Rights and Data Sharing (Articles 16–18) According to the Measures, Natural persons, legal persons, or unincorporated organizations that believe their rights have been infringed through data handling by regulators may seek administrative reconsideration or file lawsuits. Regulators are encouraged to explore data sharing mechanisms that support identity verification, credit-building, and platform governance.
8. Liabilities and Extended Applicability (Articles 19–21) Online platforms that fail to comply with reporting requirements will face legal penalties under relevant laws. Other online sellers, including those using self-built websites or alternative online channels, must comply with the Measures by reference.
II. Impacts on Enterprises and Strategic Recommendations 1. Rising Compliance Thresholds The implementation of the Measures raises the bar for compliance, requiring platforms to establish more comprehensive mechanisms for data collection, structuring, storage, and reporting. While this increases operational cost, it enhances platform legitimacy and reliability.
2. Accelerated Technical System Development To meet reporting standardization and automation goals, platforms should upgrade technical capabilities—including systems that support automated submission, real-time reporting, and traceable data pipelines.
3. Strengthened Internal Governance and Risk Control Platforms should appoint dedicated personnel or teams for data compliance. Responsibilities include reviewing data flows, maintaining documentation, monitoring for abnormal behavior, and ensuring internal alignment with regulatory requirements.
4. Proactive Legal Risk ManagementIt is advisable to establish preemptive review mechanisms for regulatory data, conduct regular compliance audits, and address errors promptly to avoid penalties or reputational harm.
[Conclusion] The implementation of the Interim Measures for the Administration of Compliance Data Reporting in Online Transactions signals a new era of data-driven and precision-focused regulation in online commerce. For platform enterprises, this represents not just a compliance challenge, but also a strategic opportunity to enhance governance capabilities.
I. Key Provisions Explained 1. Scope and Applicability (Articles 1–3) The Measures apply to online transaction platform operators within the territory of the People’s Republic of China, requiring them to report compliance data generated domestically to market supervision authorities. This includes traditional e-commerce platforms, social media platforms, live-streaming commerce providers, and others. According to the Measures, “Compliance data” refers to:1) Identity information of online business operators;2) Clues related to violations of law;3) Data required for enforcement assistance;4) Transaction data concerning specific goods or services.
2. Reporting Principles (Article 4) The Measures require adherence to the principles of balancing development and security, legality, and necessity. Emphasis is placed on:1) Protecting the legitimate rights of platform operators and consumers;2) Preventing excessive data collection and the disclosure of trade secrets and personal privacy;3) Avoiding interference with the normal operations of platforms and their users.
3. Regulatory Responsibilities (Articles 5–6) According to the Measures, the SAMR is responsible for national-level planning and oversight, while local market supervision departments manage data reporting and administration within their jurisdictions. The Measures encourage the use of automated systems and open data interfaces to improve efficiency and standardization in data submission.
4. Detailed Reporting Requirements (Articles 7–10) The Measures provides that enterprises must report the following to provincial-level regulators:1) Basic identity information of the platform and merchants;2) Special markings for merchants with annual transactions over RMB 100,000;3) Reports of violations by merchants within five working days of administrative action;4) Assistance in providing transaction-related data (payments, logistics, after-sales, etc.);5) Data on sales, volume, and prices of specified goods/services by time period or region.
5. Correction and Supplement Mechanisms (Articles 11–12) The Measures require, when submitted data is found to be inaccurate or incomplete, regulators may request corrections or supplementary submissions within five working days. Platforms may also proactively apply for corrections if errors are identified.
6. Data Use and Security (Articles 13–15) According to the Measures, regulators may use the reported data for lawful supervision, analytics, and service delivery purposes, but must not exceed their legal authority. Strict compliance with the Data Security Law, Cybersecurity Law, and Personal Information Protection Law is required to prevent abuse or unauthorized disclosure.
7. Rights and Data Sharing (Articles 16–18) According to the Measures, Natural persons, legal persons, or unincorporated organizations that believe their rights have been infringed through data handling by regulators may seek administrative reconsideration or file lawsuits. Regulators are encouraged to explore data sharing mechanisms that support identity verification, credit-building, and platform governance.
8. Liabilities and Extended Applicability (Articles 19–21) Online platforms that fail to comply with reporting requirements will face legal penalties under relevant laws. Other online sellers, including those using self-built websites or alternative online channels, must comply with the Measures by reference.
II. Impacts on Enterprises and Strategic Recommendations 1. Rising Compliance Thresholds The implementation of the Measures raises the bar for compliance, requiring platforms to establish more comprehensive mechanisms for data collection, structuring, storage, and reporting. While this increases operational cost, it enhances platform legitimacy and reliability.
2. Accelerated Technical System Development To meet reporting standardization and automation goals, platforms should upgrade technical capabilities—including systems that support automated submission, real-time reporting, and traceable data pipelines.
3. Strengthened Internal Governance and Risk Control Platforms should appoint dedicated personnel or teams for data compliance. Responsibilities include reviewing data flows, maintaining documentation, monitoring for abnormal behavior, and ensuring internal alignment with regulatory requirements.
4. Proactive Legal Risk ManagementIt is advisable to establish preemptive review mechanisms for regulatory data, conduct regular compliance audits, and address errors promptly to avoid penalties or reputational harm.
[Conclusion] The implementation of the Interim Measures for the Administration of Compliance Data Reporting in Online Transactions signals a new era of data-driven and precision-focused regulation in online commerce. For platform enterprises, this represents not just a compliance challenge, but also a strategic opportunity to enhance governance capabilities.