On January 2, 2026, the National Data Administration (NDA) published the summary of National Data Working Meeting (hereinafter referred to as “the Working Meeting”) that was held on December 29 and 30 of 2025. It reviewed the achievements of data initiatives in 2025 and outlined comprehensive priorities for 2026, and explicitly stated that 2026 will “accelerate the cultivation of an open, shared, secure national integrated data market” and, which signals that China is constructing a unified national framework of rules for data market access and operational conduct.

The key takeaways and suggestions for foreign stakeholders of the Working Meeting include: -  Determination of data asset ownership enters substantive implementation phase: the Working Meeting identified “implementing the determination of data asset ownership” as a key task for 2026, explicitly stating the need to “strengthen data asset management”. The mechanism for determining data asset ownership will directly affect the legal status and compliance boundaries for foreign companies holding, operating, and trading data assets within China, particularly in scenarios involving cross-border corporate data asset attribution and disposition. -  Public data development and use provide participation channels: It proposed to “continue implementing the ‘Data Element ×’ initiative and pilot demonstration projects for public data operation”, which is likely to aim at promoting the societal development and utilization of public data resources. From a compliance perspective, public data authorized operation will be accompanied by corresponding access conditions, operational specifications, and security requirements. Foreign companies interested in participating in China’s public data development and utilization projects should monitor subsequent authorization operation standards and scenario implementation guidelines to be issued.

-  Cross-border data flow management system continues to be refined: In summarizing 2025 achievements, the Working Meeting mentioned “deploying cross-border data flow service infrastructure and formulating industry-specific cross-border data guidelines” and listed “strengthening cross-border data flow management” as a key task for 2026. For foreign companies with cross-border data transfer needs, the issuance of industry-level cross-border data guidelines will directly influence compliance pathway selection and compliance costs.

-  AI data usage faces dual compliance requirements (ethics and security): It explicitly stated that 2026 will “strengthen data empowerment for AI development” and “implement data ethics norms to ensure data security.” For foreign companies supplying AI products, algorithm models, or engaging in large-scale data training in the Chinese market, data ethics norms will become a new compliance review dimension.

-  Data Security Becomes a Cross-Cutting Compliance Baseline: Data security content occupied a substantial portion of the Conference documents. Although significant repetition occurred in the latter sections, the policy intent is clear: data security has been positioned as a holistic, fundamental red line for data work. Specific directions relevant to foreign companies include data security technology R&D, data security rule of law construction, international cooperation on data security, data security risk prevention and control, and emergency response. Notably, the Conference repeatedly emphasized “strengthening data security rule of law construction and improving the data security laws and regulations system”, foreshadowing new legislation or regulatory revisions in the data security domain.

In all, China‘s data policy focus seems to shift] from “establishing foundational institutions” to “systematic advancement and market-oriented operations”. More actions and specific approach will be reflected in the standard system construction and the works for SAC/TC609 are advised to be closely follow-up.