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DCC · DATA COMPLIANCE CHINA China data law, for overseas counsel.
§ TAG · MINORS-PROTECTION

Filed under minors-protection

Every brief tagged "minors-protection".

  • § 01 · MINORS

    Draft State Council Provisions on Minors' Internet Use: A Ban on Stranger Social Networking, Minors' Mode by Default Under 16, and Filing for Devices and Platforms

    On September 18, 2026, the Cyberspace Administration of China (CAC) released the draft State Council Provisions on Ensuring Minors' Healthy and Safe Use of the Internet for public comment. Comments closed October 17, 2026. DCC has translated the 25 articles, the notice, and the CAC's Explanation in full. Against the 2024 Regulations on the Protection of Minors in Cyberspace, the draft adds five things. It bans online social networking with strangers for minors (except self-supporting 16- and 17-year-olds), and extends the virtual-intimacy ban from AI companions to all network services. It makes minors' mode the only way to serve under-16s with audio and video, live-streaming, games, social networking, and AI services that may affect minors' cognition. It turns minor-user identification into a stand-alone duty, with methods that include one-time facial verification and behavioral recognition. It reaches smart terminal manufacturers and app distribution platforms. And it creates a minors' mode filing system: providers that offer a minors' mode file with the provincial cyberspace administration, while platforms identified as having a very large number of minor users and a significant impact on minors file with the national cyberspace administration through the provincial office and report on their minors' mode. Fines reach 10 times illegal gains or RMB 1 million. The effective date is blank, but the year reads 2026.

    minors · minors-protection · cac
  • § 02 · MINORS

    CAC Opens the First Identification Round for 'Article 20' Platforms: Who Must Self-Report a Large Minor Audience, and by When

    On October 16, 2026, the Cyberspace Administration of China (CAC) launched the first round of identification under the Measures for Identifying Network Platform Service Providers with a Very Large Number of Minor Users and a Significant Impact on Minors (国信办发文〔2026〕2号, effective April 1, 2026). DCC translates the announcement and its work guide in full. Platforms that meet the numeric thresholds must self-assess and file within 20 working days, which on DCC's count lands in mid-November 2026. The thresholds are 10 million registered or 1 million monthly active users for minor-directed services, and 10 million registered or 1 million monthly active minor users for general-audience services. Platforms caught by a six-factor impact test are expected to file too. Paper filings go to the provincial cyberspace administration. Platforms on the final list take on the extra duties of Article 20 of the Regulations on the Protection of Minors in Cyberspace: minors-impact assessments, a minors' mode, an independent external supervisory body, platform rules, and an annual social responsibility report. For serious breaches of two of them (the impact assessment, and cutting off harmful on-platform businesses), Article 54 allows fines of up to RMB 50 million or 5% of the previous year's turnover.

    minors · minors-protection · cac
  • § 03 · PERSONAL-INFORMATION

    China Finishes the Other End of PIPL: The Draft Provisions for Large Personal Information Handlers, Read Against Order No. 25

    On 7 August 2026 the CAC published the Provisions on Personal Information Protection for Large Personal Information Handlers (Draft for Comment), consolidating its September 2025 supervision-committee draft and its November 2025 large-network-platform draft into one 50-article instrument, with comments due 7 September 2026. DCC has translated the full text and reads it against CAC/MPS Order No. 25, the small-handler regime published sixteen days earlier — because the pair is the story. Three shifts matter most. The subject changes from 'large network platform' to 'large personal information handler,' and the old registered-user and monthly-active-user tests give way to a three-factor test starting at 10 million data subjects, which reaches banks, insurers, carriers, hospitals and automakers that never thought of themselves as platforms. Designation is declared rather than automatic: a qualifying handler must self-declare through its provincial CAC and the national CAC publishes a public list, which puts the burden of self-identification on the company. And the obligations that follow are structural rather than procedural — absolute domestic storage under Article 13, a nationality requirement for data center controllers under Article 14, a protection officer drawn from management with a direct reporting line to the provincial CAC, and a supervision committee that is not a committee of the board. DCC sets out the full comparison table, the designation trap, and what the newly visible middle band means for foreign-invested subsidiaries.

    personal-information · pipl · large-platforms
  • § 04 · MINORS-PROTECTION

    The School Is Not a Bystander: Three Model Cases on Schools' Duties in Minors' Online Protection

    Minors' online protection is usually framed as a job for parents and platforms. Three model cases — a Guangzhou Internet Court judgment on defamation in a parent–school WeChat group, a Supreme People's Procuratorate case where procuratorial recommendations pushed a school to build bullying-control systems after a privacy video spread, and a Zhejiang case where a predator used an unauthorized school-named 'confession wall' account to reach students — show Chinese courts and procuratorates deliberately pulling schools into the frame. JunHe's education team distills the school's three statutory functions: internet-literacy education (Minors Protection Law Arts. 64 and 70, Online Protection Regulations Art. 16), cyberbullying prevention and response (Minors Protection Law Art. 39; School Protection Provisions Art. 21), and internet-addiction intervention (Minors Protection Law Art. 71; Regulations Art. 40). The liability stack for schools that do nothing: administrative correction orders and sanctions under Regulations Art. 51, plus civil supplementary liability under Civil Code Art. 1201. Four recommendations follow: documented literacy and AI-content-discrimination education, a staffed-up 'rule-of-law vice principal' mechanism, a full discover–stop–report–handle bullying protocol, and compliance with device-management and anti-addiction requirements. With 196 million minor netizens at 97.3% penetration, the authors argue schools are the 'main battlefield' whether they like it or not.

    minors-protection · cyberbullying · privacy
  • § 05 · AI-COMPANION

    Doubao, Qwen, and NetEase Pull AI Companions Ahead of July 15 — Is Delisting to 'Stay Safe' the Right Move?

    Days before the AI Anthropomorphic Interaction Measures take effect on July 15, 2026, Doubao, Qwen, and NetEase removed agent-style companion features — and at least one AI company had already received a question list from regulators. This translated report from 竞争秩序场 (reporter Wang Jun) maps why the industry calls the rules right in direction but hard in practice: scoping ambiguity around role-play on general-purpose models and UGC agent builders, 'capability regulation' that runs through model training and operations rather than content filters, the psychology-grade judgment needed to spot excessive emotional dependence, and expert warnings that clumsy intervention or perceived surveillance of intimate chats could do its own harm. Includes proposals for public safety-capability toolkits for smaller developers.

    ai-companion · anthropomorphic-interaction · enforcement-signals
  • § 06 · AI-COMPANION

    Ten Questions Before July 15: A Compliance Q&A on China's AI Anthropomorphic Interaction Measures

    Two days before the Interim Measures for the Management of AI Anthropomorphic Interaction Services take effect on July 15, 2026, compliance practitioners Chen Huan and Li Qiyao distill the final text into ten questions AI companies keep asking: what counts as an anthropomorphic interaction service (and what is excluded), the content red lines, training-data duties, mandatory registration fields including age and emergency contacts, the two-hour usage reminder, the ban on virtual intimate relationships for minors, the separate-consent gate on training with sensitive interaction data, the five security-assessment triggers, and the penalty ladder topping out at RMB 200,000 where life and health are harmed.

    ai-companion · anthropomorphic-interaction · minors-protection
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