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DCC · DATA COMPLIANCE CHINA China data law, for overseas counsel.
§ TAG · ENFORCEMENT

Filed under enforcement

Every brief tagged "enforcement".

  • § 01 · ENFORCEMENT

    MPS Testing Center Names 35 Apps for Personal-Information Violations: A Finance-Heavy Batch, and 15 Takedowns From the Last One

    On October 30, 2026, the National Cybersecurity Notification Center published a Ministry of Public Security notice: the MPS Computer Information System Security Product Quality Supervision and Testing Center found 35 mobile apps collecting or using personal information unlawfully. The apps were tested between August 17 and September 11, 2026. This is the first notice in the MPS app-testing series that DCC has covered, and DCC translates it in full with a consolidated table of all 35 apps. Collection and use without the user's consent accounts for 30 of the 46 findings. The other seven categories, each cited against one to seven apps, cover incomplete or inaccurate notice, unlisted third-party sharing, permissions requested without stating their purpose, forced consent to non-necessary data, collection beyond the necessary scope, no effective account cancellation, and no convenient channel to exercise rights. The batch leans heavily toward finance: by their names alone, at least ten are wealth-management, fund, brokerage, or stock-picking apps. Every app was sampled from a mainstream app store, with Apple's the largest source. The notice also reports that 15 of the previous batch's 42 apps failed retest and were taken down by distribution platforms.

    enforcement · mps · app-compliance
  • § 02 · ENFORCEMENT

    MIIT Public-Naming Bulletin 2026 Batch 5 (Total Batch 58): 26 Apps and SDKs Named, With Auto-Renewal, Misleading Downloads, and Non-Compliant Use in the Findings

    On August 25, 2026, MIIT's Information and Communications Administration Bureau issued its fifth public-naming bulletin of 2026 (total Batch 58), citing 26 apps and SDKs for conduct infringing user rights. DCC translates the bulletin and the full 26-entry annex, taken from the PDF on MIIT's website. The findings run to 48 across eleven categories. Seventeen entries drew non-compliant collection of personal information, and eight drew non-compliant use, a category absent from Batch 4. Two categories reach past personal information altogether: a non-compliant auto-renewal service and deceiving or misleading users into downloading an app. Seven of the 26 are education or study apps, two of them gaokao application planners. A city-run media center, a piano maker, and three SDKs, one an ad SDK, complete the profile.

    enforcement · miit · app-compliance
  • § 03 · ENFORCEMENT

    MIIT Public-Naming Bulletin 2026 Batch 6 (Total Batch 59): 17 Apps and SDKs Named, With Mini-Programs, Forced Targeted Push, and Store-Listing Disclosure in the Findings

    On October 15, 2026, MIIT's Information and Communications Administration Bureau issued its sixth public-naming bulletin of 2026 (total Batch 59), citing 17 apps and SDKs for conduct infringing user rights. DCC translates the bulletin and transcribes the 17-entry image table in full. The findings run to 30 across eleven categories. Fourteen entries drew non-compliant collection of personal information. Two categories are new to the MIIT batches DCC has covered: inadequate display of app information on a distribution platform, and swipe-triggered window redirects. Two more, non-compliant use of personal information and forcing users to accept targeted push, first appeared in Batch 5. Eight of the 17 were sampled inside super-apps rather than app stores: three WeChat mattress-brand mini-programs, an Alipay mini-program, a Douyin listing, and three Kuaishou listings. Three Android SDKs, one of them an ad SDK cited for inadequate SDK information disclosure, complete the list.

    enforcement · miit · app-compliance
  • § 04 · ENFORCEMENT

    CVERC Names 82 Apps for PI Violations, and 28 From Its August Batch Are Now Off the Stores

    On 23 September 2026 the National Computer Virus Emergency Response Center (国家计算机病毒应急处理中心, CVERC) named 82 mobile apps whose collection and use of personal information failed its testing, carried out between 29 July and 4 September under the 2026 CAC + MIIT + MPS joint special campaign. The notice is published as text, and DCC translates it in full: twelve violation categories, 118 findings, and every app, consolidated into one table. Three things set it apart from the MIIT and CAC notices in DCC's tracker. First, a published retest loop: of the 75 apps CVERC named in August, 28 still failed on retest and have been taken down by the distribution platforms. Second, the taxonomy has moved past the 2019 Identification Method into PIPL's statutory text. Five categories track PIPL Articles 23, 24, 30, 31 and 51 almost word for word: separate consent for sharing with another handler, an opt-out from automated-decision push, notice of why sensitive personal information is needed, dedicated rules for children under 14, and security measures. Third, the perimeter: 29 mini-programs on WeChat, Baidu and Alipay, three WeChat service accounts, two TV apps, a standalone ad SDK, and twelve builds downloaded from third-party download sites. Eight hospital channels are named, among them United Family Healthcare's mini-program, and hospitals account for four of the eleven findings of sharing personal information without separate consent.

    enforcement · cverc · app-compliance
  • § 05 · ENFORCEMENT

    CAC's 15 September 2026 Enforcement Typical Cases (执法典型案例) — Ten Cases, and the Four That Change How You Test

    On 15 September 2026 the Cyberspace Administration of China (国家网信办) published ten enforcement typical cases (执法典型案例) across cybersecurity, data security and personal information protection. Six are the familiar perimeter failures — weak passwords, unpatched vulnerabilities, unauthorized-access holes, an app forcing unnecessary permissions. Four are new, and they are the ones that should change how compliance teams test: a Chongqing property company fined for running facial recognition on 5,000+ customers for marketing without separate consent, apparently the first public penalty to turn directly on PIPL Article 26; a Shanghai company fined for exporting personal information through a Windows desktop client with no data-export security assessment; a Sichuan company's WeChat mini-program ordered offline for failing to add explicit and implicit labels to AI-generated content; and a Jiangsu company warned for running two websites as an "API relay station" (API中转站) over third-party LLM APIs without a security assessment. DCC tables all ten from the CAC notice and reads the four against PIPL, the Cross-Border Data Flows Provisions, the AI Content Labeling Measures and the 2018 Security Assessment Provisions.

    enforcement · cac · typical-cases
  • § 06 · ENFORCEMENT

    公安部网安局 Publishes 10 Typical Cases of Infringing Citizens' Personal Information — Insiders, Order Decryption, and Article 253a in Practice

    On 11 August 2026 the MPS Cyber Security Bureau (公安部网安局) published ten typical cases (典型案例) of the crime of infringing upon citizens' personal information, brought under the Clean Net special campaign (净网专项行动). Across the batch: 123 suspects, more than 9.6 million items of personal information, and roughly 23.6 million yuan in case value. The striking feature is not the volume but the access route — in at least half the cases the data came out through someone with legitimate access: an employee, a planted hire, a service vendor, a hotel partner, or a school and hospital staffer. This DCC brief translates all ten fact patterns, sets them against Criminal Law Article 253a and the 2017 PI Criminal Interpretation thresholds, and draws out what the batch signals for companies whose exposure runs through their own staff and vendors.

    enforcement · criminal-liability · mps
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