Notice of the Cyberspace Administration of China on Soliciting Public Comments Regarding the “Regulations on Promoting and Standardizing the Application of Electronic Documents

    Notice of the Cyberspace Administration of China on Soliciting Public Comments Regarding the “Regulations on Promoting and Standardizing the Application of Electronic Documents (Draft for Comment)”

    To promote and standardize the application of electronic documents, enhance the digitalization of goods trade and transportation, reduce logistics costs across society, safeguard the legitimate rights and interests of parties involved in electronic document activities, and protect national security and public interests, our Office, in collaboration with relevant departments, has drafted the “Regulations on Promoting and Standardizing the Application of Electronic Documents (Draft for Comment)” in accordance with relevant laws and regulations. We now solicit public feedback on this draft. Comments may be submitted through the following channels and methods:

    1. Email to: dzdz@cac.gov.cn.

    2. Mail to: Bureau of Informatization Development, Cyberspace Administration of China, No. 15 Fucheng Road, Haidian District, Beijing 100048. Please mark the envelope with “Comments on the Draft Regulations on Promoting and Standardizing the Application of Electronic Documents.”

    The deadline for feedback is October 13, 2025.

    Attachment: Regulations on Promoting and Standardizing the Application of Electronic Documents (Draft for Comment)

    State Internet Information Office

    September 13, 2025

    Regulations on Promoting and Standardizing the Application of Electronic Documents

    (Draft for Comment)

Chapter I General Provisions

    Article 1 These Regulations are formulated to promote and standardize the application of electronic documents, enhance the digitalization of goods trade and transportation, reduce logistics costs across society, safeguard the lawful rights and interests of parties involved in electronic document activities, and protect national security and public interests. They are based on laws and administrative regulations including the Electronic Signature Law of the People's Republic of China, the Cybersecurity Law of the People's Republic of China, the Data Security Law of the People's Republic of China, the Personal Information Protection Law of the People's Republic of China, and the Maritime Code of the People's Republic of China.

    Article 2 For the purposes of these Regulations, “electronic documents” refer to documents in the form of data messages that can prove the existence of legal relationships between parties concerning goods transportation, warehousing, cargo insurance, etc. They include electronic bills of lading, electronic multimodal transport documents, electronic ocean bills of lading, electronic railway consignment notes, electronic air waybills, electronic warehouse receipts, electronic cargo insurance policies, and other similar documents. Electronic documents include negotiable electronic documents and non-negotiable electronic documents.

    The term “electronic document system” as used herein refers to an information system based on network information technology that provides technical services for receiving, storing, and transmitting electronic document information.

    The term “electronic document system operator” as used herein refers to an institution or organization responsible for constructing and operating an electronic document system, providing the public with services such as the issuance, storage, modification, conversion, transfer, pledge, and circulation of electronic documents.

    The term “service support provider for electronic document systems” as used herein refers to institutions or organizations that provide support or services to ensure the effective operation of electronic document systems.

    The term “user of electronic document systems” as used herein refers to institutions, organizations, or individuals utilizing electronic document systems.

    Article 3:

The principles of balancing development and security, and combining innovation promotion with law-based governance shall be upheld. The promotion and application of electronic documents shall be encouraged, with electronic document systems managed by classification and tier to enhance the digitalization and facilitation of goods trade and transportation.

    Article 4:

The national cyberspace administration and relevant departments of the State Council, including industry and information technology, public security, transportation, commerce, customs, taxation, market regulation, and finance, shall strengthen policy coordination and promote and regulate the application of electronic documents according to their respective responsibilities.

    Article 5 Relevant industry organizations shall strengthen self-regulation, establish sound self-discipline systems and industry standards, and promote the standardized application and thriving development of electronic documents.

    Article 6 Relevant state departments shall advance international exchanges and cooperation in the field of electronic documents, participate in the formulation and promotion of relevant international rules, and facilitate international mutual recognition.

    Relevant enterprises and research institutions are encouraged to deepen interactions with international organizations and alliance bodies, extensively engage in international business cooperation in the field of electronic documents, and actively participate in international standardization efforts.

Chapter II Promotion of Electronic Document Application

    Article 7 Institutions and enterprises in areas such as goods trade, logistics, and finance are encouraged to recognize and utilize electronic documents in their business operations, enhance the digitalization of business applications, and promote industry quality and efficiency improvements. Financial institutions are encouraged to explore the use of new payment methods such as digital renminbi for cross-border payments based on the characteristics of electronic documents, while ensuring compliance with laws and regulations and maintaining controllable risks. They should actively and prudently innovate financial products and service models.

    Article 8:

Relevant enterprises, research institutions, industry organizations, and public service institutions are encouraged to collaborate in technological innovation, transformation of scientific achievements, and risk prevention in the field of electronic documents. They should share practical experience to promote the development and application of electronic document technology.

    Article 9: Relevant state departments shall, within their respective jurisdictions, strengthen standard-setting in the field of electronic documents. They shall promptly organize the formulation of national and industry standards, encourage participation from industry associations, industrial technology alliances, and other social organizations and relevant enterprises in the development of electronic document standards, orderly advance the conversion of existing industry standards into national standards, and actively promote the transformation of mature domestic standards into international standards.

    Article 10 Operators of electronic document systems and service providers supporting such systems shall comply with relevant laws, administrative regulations, mandatory national standards, and other normative requirements when conducting electronic document business activities.

    Operators of electronic document systems and service providers supporting such systems are encouraged to adopt recommended national standards and industry standards related to electronic documents, promptly benchmark against international standards and advanced foreign standards, and enhance mutual recognition and sharing of electronic document information.

    Article 11. Electronic document system operators, service providers, and users are encouraged to evaluate the implementation effectiveness of electronic document standards. They shall provide feedback on standard implementation to national and industry standard-setting bodies and propose revisions to standards to promote continuous optimization and adapt to industry development needs.

    Article 12. Electronic document system operators shall establish operational rules, verify users' identity information in accordance with the law, and enter into service agreements with users to clarify the rights and obligations of both parties, requiring users to commit to complying with legal provisions and operational rules.

    Service providers related to electronic document systems shall enter into service agreements with electronic document system operators, clearly defining the rights and obligations of both parties.

    Article 13. China's electronic document system operators are encouraged to provide cross-border business services to domestic and international users in compliance with laws and regulations under the national framework for cross-border data security management, thereby promoting the application of electronic documents in international trade and transportation.

Chapter III Reliability and Security of Electronic Document Systems

    Article 14 Relevant institutions, organizations, and individuals are encouraged to engage in activities such as the issuance, storage, modification, conversion, transfer, pledge, and circulation of electronic documents through reliable electronic document systems.

    A reliable electronic document system shall achieve the following functions:

    (1) Ensure the traceability and tamper-proof integrity of electronic document information throughout its lifecycle;

    (2) Identify the issuer of electronic documents;

    (3) Where supporting conversion between electronic and paper documents, ensure consistency of information before and after conversion, and reflect relevant conversion details within the documents.

    A reliable electronic document system providing services for transferable electronic documents shall also achieve the following functions:

    (1) Be capable of identifying electronic documents and ensuring their uniqueness;

    (2) Ensure that electronic documents remain under exclusive control from generation until they cease to be valid, and be capable of identifying their controller;

    (3) Ensure that control over electronic documents transfers upon their transfer.

    Article 15 The reliability of an electronic document system refers to its ability to operate stably and continuously while providing services for activities such as issuing, storing, modifying, converting, transferring, pledging, and circulating electronic documents, thereby fulfilling the functions specified in Article 14 of these Regulations.

    Factors for evaluating the reliability of an electronic document system include:

    (1) Operational rules applicable to the system;

    (2) Safeguards for the integrity of data stored in the system;

    (3) Requirements for the reliability of electronic signatures within the system;

    (4) Capabilities to prevent unauthorized access or use of the system;

    (5) Security of the hardware and software used by the system;

    (6) Stability of the system's operation;

    (vii) The disaster recovery capability of the system;

    (viii) Whether the system undergoes regular audits by independent institutions, along with the frequency and scope of such audits;

    (ix) The certification of the system's reliability issued by the certification authority referred to in Article 17(1) of these Regulations;

    (x) Relevant technical standards;

    (xi) Other relevant factors.

    Article 16. Electronic document system operators and users are encouraged to utilize electronic identity verification service systems that comply with national standards and possess functions such as enterprise user identity verification and authentication, authorized operations, self-management, on-demand provisioning, and security and reliability. These systems should effectively support the secure and reliable operation of electronic document systems. Additionally, the use of authoritative anonymous identity authentication systems, such as the national network identity authentication public service with natural person identity verification capabilities, is encouraged to ensure the security and convenience of goods trade and transportation.

    Article 17: Electronic document system operators are encouraged to apply for system reliability certification from legally established certification bodies to standardize the construction and operation and maintenance services of electronic document systems.

    The reliability certification of electronic signatures used by electronic document issuers shall be implemented in accordance with the requirements of the Electronic Signature Law of the People's Republic of China and other relevant laws and administrative regulations.

    Article 18. Electronic document system operators shall strengthen risk management, improve business processes, and support relevant parties in verifying electronic document information during issuance to prevent risks of discrepancies between the goods information recorded in electronic documents and the actual goods information.

    Article 19. Electronic document system operators shall comply with the Cybersecurity Law of the People's Republic of China and other relevant laws, administrative regulations, and national provisions. They shall use technologies and equipment that meet national security standards, implement the cybersecurity grading protection system, and ensure the cybersecurity of electronic document systems and electronic documents.

    Electronic document system operators shall establish and improve cybersecurity technical measures, continuously monitor system operation status, and promptly address abnormal situations. They shall formulate cybersecurity incident emergency response plans. Upon occurrence of a cybersecurity incident, they shall immediately activate the emergency response plan, take corresponding remedial measures, and report to the competent authorities in accordance with relevant regulations.

    Where an electronic document system constitutes critical information infrastructure, the electronic document system operator shall also fulfill the cybersecurity obligations incumbent upon operators of critical information infrastructure.

    Article 20 Operators and users of electronic document systems shall comply with laws, administrative regulations, and relevant national provisions such as the Data Security Law of the People's Republic of China and the Personal Information Protection Law of the People's Republic of China when processing electronic document data. They shall strengthen the classification and grading protection of electronic document data, ensure the data security of electronic document systems, and safeguard the personal information rights and interests of users and relevant entities of electronic document systems.

    The storage of electronic document data shall comply with the provisions on data storage and data security established by the relevant competent authorities according to the industry and type to which it belongs.

    Article 21. The provision of data related to electronic documents to foreign countries shall comply with the relevant national provisions on data transfer abroad. Data related to electronic documents collected or generated during international trade or cross-border transportation may be provided overseas without undergoing data outbound security assessments, entering into standard contracts for personal information outbound transfers, or obtaining personal information protection certification, provided that such data does not contain personal information or important data, or the personal information involved is strictly necessary for issuing, transferring, pledging electronic documents, or exercising rights associated with electronic documents.

Chapter IV Supervision, Inspection, and Legal Liability

    Article 22 The national cyberspace administration, in conjunction with relevant national competent authorities, shall formulate corresponding classification and grading management rules or guidelines based on the types, technical characteristics, and industry features of electronic documents, in accordance with relevant laws and administrative regulations. This aims to improve management approaches and encourage the application and innovative development of electronic documents.

    Article 23 Relevant competent authorities shall, within their respective jurisdictions, conduct supervision and inspection of the construction, operation, and business activities of electronic document systems. Operators of electronic document systems, service providers supporting such systems, and relevant parties shall cooperate in accordance with the law. The implementation of supervision and inspection by relevant authorities shall not interfere with the normal production and business activities of the inspected entities.

    Relevant institutions and personnel participating in supervision and inspection shall keep confidential state secrets, trade secrets, personal privacy, and personal information learned in the course of performing their duties in accordance with the law, and shall not disclose or unlawfully provide such information to others.

    Article 24 Where operators of electronic document systems, service providers related to such systems, or relevant parties violate the provisions of these Regulations, the competent authorities shall impose penalties in accordance with the provisions of laws and administrative regulations such as the Electronic Signature Law of the People's Republic of China, the Cybersecurity Law of the People's Republic of China, the Data Security Law of the People's Republic of China, and the Personal Information Protection Law of the People's Republic of China. Where laws or administrative regulations do not provide for penalties, the competent authorities shall issue warnings and order rectification within a specified time limit based on their duties. Where rectification is refused or the circumstances are serious, the provision of relevant services shall be ordered to be suspended. Where a crime is constituted, criminal liability shall be pursued in accordance with the law.

Chapter V Supplementary Provisions

    Article 25 These Provisions shall come into force on [Month] [Day], [Year].