China has taken a step forward to safeguard children’s rights and privacy. It has introduced a mandatory annual reporting requirement for all data controllers who process the personal data of children, defined as minors under the age of 14.

This requirement is a new formal filing that supplements the existing requirement for annual internal audits under the Measures on the Protection of Minors in Cyberspace.

Who Must Comply?

The rule applies to all data controllers—regardless of volume—that process the personal data of minors under 14.

This means that even if a company processes a child’s data incidentally (such as an employer processing the data of an employee’s dependent), they are subject to this requirement.

What Needs to be Reported?

Data controllers must submit a formal summary report to the Cyberspace Administration of China (CAC), China’s data regulator, summarizing the results of their annual audit.

The report must include key information such as:

1. The overall conclusions of the audit.
2. Key compliance gaps identified and the proposed remediation actions.
3. The channels (e.g., apps, websites) through which minors’ data is collected.
4. The volume of data subjects under 18 and under 14.

The underlying audit must ensure compliance with the Personal Information Protection Law (PIPL), paying close attention to minor-specific rules like parental consent, age verification methods, and dedicated minor data protection policies.

When is the Deadline?

The initial report for processing activities conducted in the preceding year (2025) is due by January 31, 2026.

Going forward, the report must be submitted by the end of January each year.

Penalties for Non-compliance

Failure to report on time is considered a violation of the PIPL. Potential penalties include:

• Fines and administrative warnings.
• Orders to make corrections or orders to suspend the relevant processing or underlying business.
• In serious cases, the Data Protection Officer (DPO) or other directly responsible personnel may face personal liability.