CAC opens personal-information protection officer filing for processors of ≥1M individuals (18 July 2025)
Analysis
By UA Ledger staff — 2 min read
CAC’s 18 July 2025 notice requires processors of personal information of 1 million or more individuals to file DPO details with prefecture-level cyberspace departments, with an 29 August 2025 catch-up deadline for those already over the threshold.
On 18 July 2025, CAC published 关于开展个人信息保护负责人信息报送工作的公告. The page we opened on 20 September 2026 cites PIPL Article 52 and Article 12 of the Personal Information Protection Compliance Audit Measures: processors that handle personal information of 1 million or more individuals must file personal-information protection officer (个人信息保护负责人) details with the prefecture-level (设区的市) cyberspace department where they are located.
Timelines on the notice
- From publication, once a processor reaches 1 million individuals’ PI, filing is due within 30 working days.
- Processors already at or above 1 million before the notice must complete filing by 29 August 2025.
- Material changes must be updated within 30 working days of the change.
Filing is online via the “个人信息保护业务系统” at https://grxxbh.cacdtsc.cn (also reachable from CAC’s national cyberspace government service hall). Failure to file is handled under applicable laws and rules.
What this notice is not
This is a filing / registration procedural notice, not a list of which game publishers or adtech firms have already filed, and not the same threshold as the >10 million biennial audit rule. The commission title’s informal “July 2025 system launch” shorthand should be read against this 18 July 2025 dated bulletin and the 29 August 2025 catch-up deadline.
Operator action
| Field | Evidence |
|---|---|
| Notice date | 2025-07-18 |
| Threshold | ≥1 million individuals’ PI |
| Filing authority | Prefecture-level cyberspace department |
| Catch-up deadline (already ≥1M) | 2025-08-29 |
| Portal | grxxbh.cacdtsc.cn |
| UA implication | Large China live-ops / adtech processors should confirm DPO filing status; do not invent a filing receipt |
Download the filing card. Keep the July/August 2025 document dates; do not backdate the obligation as a 2026 invention.
Research checked 20 September 2026. Local draft; human editorial review pending.
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