On April 3, 2026, China’s National Data Administration (NDA) issued the Draft Guidelines for Data Property Registration (Trial) for Public Comment (数据产权登记工作指引（试行）》（公开征求意见稿）). These draft national Guidelines follow the limited data registration pilots in Beijing, Shanghai, and Shenzhen. While the Guidelines don’t propose a new enforcement right, registered data certificates may be useful as an intangible asset that can be listed on a corporate balance sheet (thereby increasing valuation) or possible as an asset for securing a loan. Comments are due April 19, 2026.
A translation follows. The original text is available here (Chinese only).
Article 1 Purpose of Formulation
In order to establish and improve the data property rights system, build a unified national data property rights registration system, and cultivate a national integrated data market, this guideline is formulated in accordance with the Civil Code of the People’s Republic of China, the Data Security Law of the People’s Republic of China, and other laws and regulations.
Article 2 Scope of Application
This guideline shall be followed in conducting data property rights registration activities and their management within the territory of the People’s Republic of China.
This guide applies to data ownership registration for all forms of data, including data resources and data products.
Article 3 Meaning of Terms
The data property rights referred to in this guide are the property rights enjoyed by the rights holder over specific data, including the right to hold data, the right to use data, and the right to manage data.
The data holding right referred to in this guide means the right of the right holder to hold legally obtained data, either by themselves or by entrusting others to hold it on their behalf.
The data usage rights referred to in this guide are the rights of the rights holder to use data to optimize production and operation and to generate derivative data through processing, aggregation, analysis, and other means.
The data management right referred to in this guide refers to the right of the right holder to provide data to external parties through paid or unpaid means such as transfer, licensing, investment, or legally established security.
The data ownership registration referred to in this guide refers to the act of a data ownership registration agency reviewing the description, source, and rights content of data in accordance with this guide, recording information such as the ownership of data rights, and issuing a registration certificate.
The registration agency referred to in this guide is a legal entity selected and determined by the national data management department, included in the national directory of data property rights registration agencies, and engaged in data property rights registration activities.
The term “registration applicant” as used in this guide refers to natural persons, legal persons, and unincorporated organizations that apply to the registration authority for data ownership registration.
Article 4 Registration Principles
Data ownership registration activities should adhere to the principles of equality, voluntariness, standardization, fairness, integrity, convenience, and efficiency.
Article 5 Management Responsibilities
The national data management department is responsible for the management of data property rights registration nationwide. Its specific responsibilities include: establishing and improving a unified national data property rights registration system; piloting and improving regulatory rules and registration details for data property rights registration agencies; guiding and supervising data property rights registration activities nationwide; managing the national data property rights registration service platform; and other responsibilities stipulated by laws and regulations.
Provincial-level data management departments are responsible for the management of data ownership registration within their respective administrative regions. Specific responsibilities include: recommending registration agencies within their jurisdiction; guiding and supervising data ownership registration activities within their jurisdiction; and other responsibilities stipulated by laws and regulations. Provincial-level data management departments may delegate specific tasks to municipal-level data management departments.
Article 6 Registration Platform
The National Data Property Rights Registration Service Platform serves the entire country, providing unified services such as publicizing data property rights registration, querying and verifying registration results, and handling objection applications, while also supporting the management of registration agencies.
Chapter Two Registration Authority
Article 7 Basic Conditions for Registration Agencies
Registration agencies should meet the following basic conditions:
(i) Legal entities such as enterprises and institutions that are legally established and operating well within the territory of the People’s Republic of China, of which the paid-in registered capital of corporate legal entities shall not be less than RMB100 million;
(ii) It has a fixed office space and the infrastructure to meet business needs;
(iii) Have more than two years of experience in data circulation services;
(iv) It has a sound governance structure, registration business management system, data security management system, data security risk disposal plan and service exit guarantee plan;
(v) A dedicated review team shall be established, and members of the dedicated review team shall have professional qualifications in data, law and other related fields and more than three years of work experience;
(vi) Establish an information system to support data property rights registration business, complete the filing of information system network security level protection level three or above, and have the basic conditions to connect with the national data property rights registration service platform;
(vii) There have been no unfair competition, abnormal business operations or other behaviors in the past three years, and there are no major violations of laws and regulations.
Article 8 Principles for the Selection of Registration Agencies
Registration agencies are recommended by provincial data management departments and selected by the national data management department. The selected registration agencies are included in the national directory of data property rights registration agencies, made public, and connected to the national data property rights registration service platform.
Article 9 Procedures for the selection of registration agencies
Provincial-level data management departments shall carry out the recommendation work in accordance with the following requirements:
(i) Organize eligible enterprises, institutions, and other legal entities to submit applications;
(ii) Conduct preliminary review of materials, expert evaluation, collective decision-making, etc., determine the recommended list, and submit it to the national data management department.
Those selected as registration agencies by the national data management department shall be organized by the provincial data management department to submit their registration agency information to the national data property rights registration service platform.
Article 10 General Requirements for Registration Agencies to Conduct Registration Business
Registration agencies may practice nationwide. Registration agencies shall conduct registration business in accordance with the following requirements:
(i) Conduct data ownership registration in an open, fair, and impartial manner;
(ii) Registration materials shall be properly preserved for a period of not less than twenty years;
(iii) Timely and accurately disclose the data property rights registration process, fee standards, complaint channels, etc., to improve work transparency and accept public supervision;
(iv) Operate and maintain the information system supporting data property rights registration business, and ensure its connection with the national data property rights registration service platform;
(v) Establish an information reporting system and promptly report relevant information on data ownership registration as required by the data management department;
(vi) The registration agency shall be obligated to keep the materials provided by the applicant confidential and shall take necessary measures to ensure data security, and shall not disclose or use them illegally;
(vii) They shall not engage in any activities that affect the impartiality or independence of the registration process, nor shall they engage in any data provision activities for profit, nor shall they apply for registration with this registration authority as the applicant for registration.
(viii) Efforts should be made to improve registration service capabilities, reduce registration costs, provide registration applicants with reasonably priced registration services, and prohibit the mandatory bundling of other fee items.
Article 11 Management of Registration Agencies
Provincial-level data management departments should strengthen the management of registration agencies and, based on regulatory needs, guide registration agencies to conduct data ownership registration business in accordance with laws and regulations through supervision, interviews, and other means. For cases of registration agencies conducting data ownership registration business in violation of laws and regulations, they should work with relevant departments to verify the situation, take effective measures, and properly handle the matter. For clues suspected of being criminal, they should transfer them to relevant departments for handling in accordance with the law.
The provincial data management department where the registration agency is located shall conduct daily management of the registration agency and accept and handle public opinions on registration activities. If a registration agency engages in illegal or irregular activities while practicing in a different location, the provincial data management department of the location of practice shall coordinate with the provincial data management department of the place of registration. If there are differing opinions and no agreement can be reached through consultation, the national data management department shall provide guidance for resolution.
The national data management department formulates annual assessment standards for registration agencies and conducts inspections of the assessment results. Registration agencies shall report on the progress of their data ownership registration business in the previous year to the provincial data management department where they are located by March 31st each year, ensuring that the submitted information is true, accurate, and complete. The provincial data management department where the registration agency is located conducts an annual assessment of the registration agency and submits the assessment results and relevant materials to the national data management department by April 30th each year.
Article 12 Information Changes of Registration Authority
If a registration authority falls under any of the following circumstances, it shall report to the provincial data management department within five working days, and after review and confirmation, update the information on the National Data Property Registration Service Platform within five working days:
(i) Those whose names have been changed;
(ii) Change of address;
(iii) Changes in the registered capital of a corporate entity;
(iv) Changes in the legal representative or controlling shareholder and actual controller of the corporate entity;
(v) Other major matters that may affect the normal operation of registration business.
Article 13 Withdrawal of the Registration Authority
If a registration agency intends to withdraw from the data property rights registration business, it shall report to the provincial data management department where it is located at least two months in advance and submit a withdrawal plan. The provincial data management department where the registration agency is located shall, within twenty working days of receiving the agency’s report and withdrawal plan, make a decision on the withdrawal plan; if it approves the withdrawal, it shall report the relevant information to the national data management department within five working days of approving the withdrawal. After review and approval by the national data management department, it shall announce the decision to the public through the national data property rights registration service platform and adjust the national directory of data property rights registration agencies.
If a registration agency withdraws from data property rights registration business, and the legal entity of the registration agency still exists, it shall retain the data and assume corresponding responsibilities; if the registration agency is merged, the surviving agency after the merger or the newly established agency shall retain the data and assume corresponding responsibilities; if the registration agency goes bankrupt or is dissolved, the provincial data management department shall designate another agency to retain the data property rights registration data on its behalf and properly handle related matters.
If a registration agency withdraws from the data property rights registration business, the data property rights registration certificates issued during the period when it carried out the data property rights registration business will not be affected.
Chapter Three Registration Procedures
Article 14 Registration Procedure
Data ownership registration is carried out in accordance with procedures such as application, acceptance, review, public announcement, objection handling, information storage, and certificate issuance.
Article 15 Registration Subjects
Data that can circulate in the market can be registered for data ownership. For data involving public resources, the following procedures apply:
(i) Data collected and generated by Party and government organs in the course of performing their duties in accordance with the law, as well as data collected by other enterprises or institutions on their behalf as required by the performance of their duties, shall not be subject to data ownership registration;
(ii) After the public data resources are authorized for operation, the public data products and services developed shall be registered on the public data resource registration platform before data ownership registration is carried out;
(iii) Unless otherwise stipulated, public utility enterprises and institutions such as water supply, gas supply, heating, power supply, and public transportation may register data ownership for the data generated in the process of providing public services.
Article 16 Registration Application
Applicants may voluntarily apply for data ownership registration with the registration authority, either independently or by entrusting another person to do so. They should submit a registration application form, along with supporting materials demonstrating the data source and ownership. All submitted materials must be true, accurate, and complete, and must not contain any false information, misleading statements, or material omissions.
Article 17 Registration and Acceptance
Upon receiving the application materials for data ownership registration, the registration authority shall process them in accordance with the following circumstances and notify the applicant of the acceptance result within three working days:
(i) If the application materials are incorrect, incomplete, or do not meet the requirements, the applicant shall be notified in writing that the application will not be accepted and shall be informed of all the materials that need to be corrected and the deadline for correction. If the applicant fails to make corrections within the deadline, it shall be deemed that no application has been submitted.
(ii) If the application materials are complete and in compliance with the regulations, or if all supplementary materials are submitted as required, the application shall be accepted and the applicant shall be notified in writing.
The registration authority may not refuse to accept a registration application without a justifiable reason. The date on which the registration authority informs the applicant of its acceptance of the application is the date on which the application is accepted.
If the registration authority fails to notify the registration applicant in writing of non-acceptance as stipulated above, it shall be deemed to have accepted the application. The first working day after the expiration of the notification period shall be deemed the date of acceptance of the registration.
Article 18 Registration Review Principles
After accepting an application for data ownership registration, the registration authority shall conduct a reasonable and prudent review of the accuracy of the data description, the compliance of the data source, and the clarity of the data ownership. The registration authority may request the applicant to provide supplementary supporting materials and, if necessary, verify with interested parties or other relevant entities.
Article 19. Data Description Accuracy Review
When reviewing the accuracy of data descriptions, registration authorities should focus on whether the data names are concise, accurate, and unambiguous. Data names should, in principle, include the time, region, industry, content, and data type.
Article 20 Compliance Review of Data Sources
The registration applicant does not own the data rights to data obtained illegally or in violation of regulations. When reviewing the compliance of data sources, the registration authority should examine the following:
(i) The legality and compliance of the data collection process should be reviewed for the collected data.
(ii) For data obtained through agreements, it should be examined whether the relevant agreements stipulate that the registration applicant enjoys the relevant data ownership rights;
(iii) For publicly available data collected through automated procedures, it should be examined whether the registered data is publicly available data and whether the means and methods by which the applicant collected the data are legal and compliant;
(iv) For data created by derivatives, first examine whether the applicant has the right to use the original data; second, examine whether the relevant agreement stipulates the ownership of the derivative data. If there is no clear stipulation, examine whether there are substantial and significant differences from the original data in terms of content, form, and structure, and whether it has a value that is significantly higher than the original data.
(v) For data involving personal information, it should be reviewed whether the acquisition of the data complies with the requirements of the Personal Information Protection Law of the People’s Republic of China and other laws and regulations;
(vi) For data involving important data, the acquisition of the data should be reviewed to ensure that it complies with the requirements of laws and regulations such as the Data Security Law of the People’s Republic of China.
Article 21 Review of Data Property Rights Clarity
The registration authority shall review the clarity of data ownership in accordance with the following requirements:
(i) Data processors may register the right to hold, use, and operate the data they collect and generate in their own or jointly participated production and operation activities, provided that such data does not violate laws, regulations, or contractual agreements;
(ii) Any entity that authorizes another to collect data generated by it based on a civil contract has the right to obtain, copy, or transfer the relevant data, and may register the right to hold, use, or operate the data;
(iii) Natural persons may register the right to hold, use, and manage the data they lawfully collect, generate, or obtain;
(iv) Data processors shall implement the requirements of the national data classification and grading protection system. For publicly available data collected through automated procedures without illegally intruding into other people’s networks, interfering with the normal operation of network services, damaging effective technical measures, or harming the legitimate rights and interests of individuals and organizations, they may register the right to hold and use the data. For data products formed without substantially replacing the products and services of the data subject, they may register the right to hold, use, and operate the data.
(v) Where multiple data processors collaborate to promote data integration and development, relevant rights shall be registered in accordance with the contract. For integrated data, where the contract does not specify or is unclear about the data ownership, each participating party may register the right to hold and use the data, and may register the right to operate the data with the consent of other participating parties.
(vi) If a data processor has the right to use the data, and under the premise of protecting the legitimate rights and interests of all parties, it achieves substantial changes in the content, form, and structure of the data by using professional knowledge to process, model and analyze, extract key information, etc., thereby significantly enhancing the value of the data and forming derivative data, the data processor may register the right to hold, use, and operate the derivative data.
(vii) Where data is entrusted to another person for processing, unless otherwise provided by law or agreed in the contract, the entrusted person shall not register the right to hold, use or operate the original data, process data and result data entrusted for processing.
The rights of ownership, use, and management are independent of each other. The same right holder may enjoy all of them, or one or more of them. For the same right to the same data, different right holders may enjoy it simultaneously without mutual exclusion.
Article 22 Circumstances under which registration will not be granted
If any of the following circumstances are found upon review, the registration authority shall refuse registration and notify the registration applicant in writing:
(i) The data involves national security, state secrets, etc.;
(ii) The data source violates the provisions of laws and administrative regulations;
(iii) There are unresolved data ownership disputes regarding the data;
(iv) The registration applicant concealed the truth or provided false evidence;
(v) Other circumstances where registration is not permitted as stipulated by laws and administrative regulations.
Article 23 Record of Restrictions on Rights
If the exercise of data rights is subject to the following restrictions, these shall be noted in the remarks:
(i) Where there is an agreement regarding the term and conditions for exercising data rights;
(ii) Seizure and other preservation measures lawfully implemented by the People’s Court, the People’s Procuratorate, the public security organs, and other competent authorities;
(iii) Temporary control measures taken by the competent administrative departments to safeguard national security and public interests;
(iv) Other matters that the registration authority deems necessary to record.
Article 24 Registration and Public Notice
If the circumstances described in Article 22 do not exist, the registration authority shall publish the registration applicant’s information, data name, data overview, and record of rights restrictions on the national data property rights registration service platform. If there are legitimate reasons, the registration applicant may apply to the registration authority for non-publication, and the registration authority shall determine this based on the actual circumstances.
The public notice period is five working days, calculated from the date the public notice is published on the National Data Property Registration Service Platform.
Article 25 Handling of Objections During the Public Notice Period
Those who raise objections to the publicized content shall provide the reasons for the objection and relevant materials. The registration authority shall investigate the objection within ten working days from the date of receipt of the objection, may request the registration applicant to provide explanations, and shall make a timely decision.
If it is found during the public notice period that a registration should not be made, the registration authority shall make a decision not to register it.
Article 26 Registration Information Storage
The registration authority shall preserve evidence of important matters and registration results during the registration process on the national data property rights registration service platform, including but not limited to the basic information of the registration applicant, basic data information, rights content, and rights restrictions, to ensure that the registration information is tamper-proof, the registration process is traceable, and the registration content is verifiable. Registration applicants may voluntarily provide data watermarks, data fingerprints, etc., for the registration authority to preserve as evidence. Registration is completed upon the preservation of the registration information.
Article 27 Issuance of Certificates
Upon completion of registration, the registration authority shall issue a certificate in accordance with the unified format and coding requirements provided by the National Data Property Registration Service Platform, and affix the registration authority’s official registration seal (see Appendix 6 for certificate examples and coding rules). In the event of any discrepancy between the content of the registration certificate and the information stored on the National Data Property Registration Service Platform, the latter shall prevail.
The data ownership registration certificate takes effect from the date of issuance and is generally valid for no more than five years. If renewal is required, a renewal registration must be processed.
Article 28 Registration Time Limit
The registration authority shall complete the data ownership registration procedures within ten working days from the date of accepting the registration application. If an extension is necessary due to the complexity of the data source or the sheer volume of data, it may be appropriately extended, but the extension period shall not exceed ten working days. Registration authorities are encouraged to optimize and innovate registration services, improve registration efficiency, and shorten registration time limits.
The time spent on supplementing supporting materials, publicizing the registration process, and handling objections shall not be included in the time limit stipulated in the preceding paragraph.
Article 29 Handling of Objections After Registration
If an applicant believes that there is an ownership dispute or an error in the data property registration, they can file an objection with the registration authority through the National Data Property Registration Service Platform. Filing an objection requires submitting an objection application form, preliminary evidence, and other materials.
The registration authority shall review whether the objection materials are complete. If the materials are complete, the registration authority shall notify the registration applicant in writing within five working days after receiving the materials.
If the applicant acknowledges the objection, the registration authority shall change the registration details or cancel the registration according to the established procedures.
If the registration applicant does not accept the content of the objection, they shall submit relevant explanatory materials to the registration authority. The registration authority may require the registration applicant and the objector to cooperate in conducting an investigation and shall issue a conclusion on the handling of the objection. If the registration applicant and the objector accept the conclusion, the registration authority shall take appropriate action based on the conclusion.
If the registration applicant or objector is dissatisfied with the registration authority’s decision, they may apply for arbitration to an arbitration institution or file a lawsuit in a people’s court, as agreed. The registration authority shall handle the matter in accordance with the effective legal documents issued by the people’s court or arbitration institution. Local data management departments with the necessary resources are encouraged to provide mediation services.
Article 30 Inquiry of Registration Information
Applicants and interested parties may inquire about and copy necessary data and property rights registration information in accordance with the law, and the registration authority shall provide such information.
Relevant state authorities may, in accordance with the provisions of laws and administrative regulations, inquire into, copy, and investigate matters related to data ownership registration information.
Entities and individuals that inquire about or copy data property registration information shall explain the purpose of the inquiry or copying to the registration authority and shall not use the obtained registration information for other purposes; without the consent of the rights holder, they shall not disclose the obtained registration information.
Article 31 Use and nationwide recognition of registration certificates
In the following activities, data ownership registration certificates can serve as proof of data ownership and content:
(i) In data circulation and trading, data ownership registration certificates shall serve as proof of data ownership;
(ii) When carrying out activities such as data entry, financing, and equity investment, the data ownership registration certificate shall be used as proof of legal ownership or control of the data;
(iii) In resolving data-related disputes and controversies, data ownership registration certificates shall be used as evidence for determining ownership;
(iv) In support policies such as the cultivation and recognition of data enterprises, data property rights registration certificates shall be used as proof to judge the data status of enterprises.
Registration agencies are encouraged to strengthen business collaboration between data property rights registration and data quality assessment, value assessment, etc., and provide full-process services to the market without affecting the fairness and independence of registration.
When providing services, data circulation service providers shall accept the registration certificates issued in accordance with this guideline and shall not conduct repeated reviews or charge fees without justifiable reasons.
Chapter Four Registration Types
Article 32 Registration Types
Data ownership registration includes initial registration, transfer registration, change registration, renewal registration, and cancellation registration.
Article 33 Initial Registration
Initial registration refers to the first registration of data ownership of specific data by the applicant with the registration authority.
For initial registration applications, applicants shall submit an initial registration application form (see Appendix 1 for a reference template), supporting documents for the applicant’s identity, supporting documents for the legal acquisition of data ownership, as well as data samples and data descriptions.
For the same data, other types of registration can only be processed after the initial registration is completed. Other types of registration are handled by the same agency that completed the initial registration.
Article 34 Transfer Registration
If the transferor has completed the initial registration and enjoys the data holding rights, usage rights, and management rights, and intends to transfer all or part of the data ownership to the transferee, and will no longer retain it, the transferor and the transferee shall jointly apply for transfer registration.
For applications for transfer registration, the applicant shall submit a transfer registration application form (see Appendix 2 for a reference template), a transfer contract, and the initial registration certificate, among other materials. If the registration authority accepts and approves the transfer registration, it shall adjust the transferor’s data property rights registration certificate accordingly.
Article 35 Change of Registration
If the change does not involve significant changes to the rights holder, data source, or type of rights, the applicant may apply for registration change under the following circumstances:
(i) Changes to the applicant’s identity information, such as name, legal representative, address, etc.;
(ii) The data description information, data time span, etc. are incorrect or have changed.
For applications to change registration, the applicant shall submit an application form for change registration (see Appendix 3 for a reference template), the initial registration certificate, supporting materials for the changes, etc.
Article 36 Renewal Registration
Within six months before the expiration of the data ownership registration certificate, the applicant may apply to the registration authority for renewal. If the data ownership registration certificate expires and no renewal application is made, the registration certificate will automatically become invalid.
For those applying for renewal of registration, the applicant shall submit a renewal registration application form (see Appendix 4 for a reference template), the initial registration certificate, etc.
Article 37 Cancellation of Registration
The registration authority will cancel the registration of registered data ownership in the following circumstances:
(i) The applicant for registration applies for cancellation;
(ii) The original rights holder’s data ownership is extinguished due to data destruction or other reasons;
(iii) The case should be cancelled according to the results of the objection handling, etc.
(iv) Other circumstances stipulated by laws and administrative regulations.
For applications to cancel registration, the applicant shall submit a cancellation registration application form (see Appendix 5 for a sample template), the initial registration certificate, and other materials required by the registration authority. If the registration authority discovers that a registration certificate should be cancelled, it may proactively cancel the registration and notify the original applicant in an appropriate manner.
Chapter Five Legal Liability
Article 38 Responsibilities of the Registration Authority
The registration agency shall bear legal responsibility for the accuracy of the registration results. If the registration agency or its staff commits any of the following acts, and the circumstances are minor, the provincial data management department where the registration agency is located shall order it to rectify the situation within a specified period and suspend its publication of registration information on the National Data Property Registration Service Platform; if the circumstances are serious or the agency refuses to rectify the situation, it shall be removed from the national directory of data property registration agencies; if the act constitutes a crime, it shall bear corresponding legal responsibility:
(i) Registering an application that does not meet the registration requirements or registering an incorrect application due to intentional misconduct or gross negligence;
(ii) Tampering with, damaging, or forging data property rights registration information and registration certificates;
(iii) Disclosing data ownership registration materials, registration information, etc., thereby harming national security, public interests, or the legitimate rights and interests of others;
(iv) Other illegal or irregular activities exist.
If the registration authority’s actions cause harm to others, it shall bear liability for damages and other similar liabilities in accordance with the law. After assuming liability, if there are other liable parties, the registration authority may seek recourse from them in accordance with the law.
Article 39 Responsibilities of the Registration Applicant
If a registration applicant commits any of the following acts, causing harm to others, they shall bear civil liability such as compensation for damages in accordance with the law; if the act constitutes a violation of the law or a crime, they shall bear corresponding liability in accordance with the law:
(i) Obtaining registration by deception, such as concealing the truth or providing false materials;
(ii) Intentionally obtaining illegitimate benefits through duplicate registration;
(iii) Actions that harm national security, public interests, or the legitimate rights and interests of others;
(iv) Other illegal or irregular activities exist.
Article 40 Responsibilities of Data Management Department Staff
Staff members of data management departments who abuse their power, neglect their duties, or engage in favoritism or fraud in the management of data property rights registration activities shall bear corresponding penalties or administrative sanctions in accordance with laws and regulations; if a crime is constituted, they shall bear criminal responsibility in accordance with the law.
Chapter Six Supplementary Provisions
Article 41 Connection with other registrations
For other types of data registrations completed before the implementation of this guideline, and where the relevant review matters are consistent with the requirements of this guideline, the registration agency may simplify the review procedures based on the specific circumstances.
Article 42. Meaning of “above” and “within”.
The terms “above” and “within” as used in this guide include the stated number.
