---
title: "China — Children & Vulnerable Groups | Data Protection Monitor"
canonical: https://dataprotection.gi/jurisdictions/china/children-and-vulnerable-groups/
source_html: /jurisdictions/china/children-and-vulnerable-groups/index.html
description: "China — Children & Vulnerable Groups: children_and_vulnerable_groups Children & Vulnerable Groups 5 sub-modules 2 claims Amber ▾ # Minors' data receives clear sensitive-category and parental-consent treatment with"
generated_at: 2026-10-25T04:46:50Z
content_sha256: 5f68b6ac913a0e4b2c3f0505d8aa59432ef2e39d9449cbf5b1069a26c912730e
generator: "fe-fleet/md-twin@1.0"
---
# China — Children & Vulnerable Groups | Data Protection Monitor

### D9Children & Vulnerable Groups5 sub-modules2 claimsAmber▾#

Minors' data receives clear sensitive-category and parental-consent treatment with active 2025-2026 filing enforcement, but dependent-adult protections and minor-specific profiling bans were not located in this research pass.

Primary framework Provisions on Cyber Protection of Children's Personal Information (2019); PIPL Art 28

Supervisory authority [Cyberspace Administration of China (CAC)](https://www.cac.gov.cn/)

Traffic-light rationale — Amber Minors' data receives clear sensitive-category and parental-consent treatment with active 2025-2026 filing enforcement, but dependent-adult protections and minor-specific profiling bans were not located in this research pass.

#### Sub-modules (5)

#### Age VerificationAmber

The operative age threshold for heightened protection is 14 years; the December 2025 CAC directive requires filings on the nature, categories and volume of minors' personal information collected, implying an age-identification/verification compliance step, though no standalone age-verification technical mandate was located.

Claims (1):

- PIPL classifies the personal information of minors under the age of 14 as sensitive personal information, and CAC's 2019 Provisions on Cyber Protection of Children's Personal Information (China's COPPA-equivalent) requires parental/guardian consent for handling children's data; a CAC directive issued 28 December 2025 further requires companies collecting minors' personal information to complete compliance audits and file supporting materials with local CAC offices by 31 January 2026.

#### Parental ConsentGreen

PIPL treats personal information of minors under 14 as sensitive personal information, requiring parental or guardian consent for processing, building on the 2019 Provisions on Cyber Protection of Children's Personal Information.

Claims (1):

- PIPL classifies the personal information of minors under the age of 14 as sensitive personal information, and CAC's 2019 Provisions on Cyber Protection of Children's Personal Information (China's COPPA-equivalent) requires parental/guardian consent for handling children's data; a CAC directive issued 28 December 2025 further requires companies collecting minors' personal information to complete compliance audits and file supporting materials with local CAC offices by 31 January 2026.

#### Minor Profiling BansRed

No standalone algorithmic-profiling ban specific to minors, distinct from PIPL's general ADM transparency/opt-out rules, was identified in this research pass.

#### Education SettingsRed

No education-setting-specific children's data protection rule was identified in this research pass.

#### Dependent AdultsRed

PIPL allows close relatives to exercise a deceased individual's data protection rights, but no dedicated regime for living dependent adults (elderly or mentally incapacitated persons) was identified.

Claims (1):

- PIPL permits close relatives of a deceased individual to exercise that individual's data protection rights, but no equivalent statutory protection specific to living dependent adults (e.g., elderly or mentally incapacitated persons) was identified.

Category narrative 96 words

PIPL treats the personal information of minors under 14 as sensitive personal information, requiring parental/guardian consent, building on the standalone 2019 Provisions on Cyber Protection of Children's Personal Information (China's COPPA-equivalent). A December 2025 CAC directive newly requires companies collecting minors' personal information to complete compliance audits and file materials (data categories/volume, impact assessment, signed undertaking letter) with local CAC offices by 31 January 2026, signaling heightened 2026 enforcement focus. No standalone minor-specific profiling ban, education-setting-specific rule, or dependent-adult (elderly/incapacitated) regime was identified beyond PIPL's general provision allowing close relatives to exercise a deceased individual's rights.

Evidence 2

Sources and claims (2)
- Probable[IAPP](https://iapp.org/news/a/notes-from-the-asia-pacific-region-strong-start-to-2026-for-china-s-data-ai-governance-landscape) — PIPL classifies the personal information of minors under the age of 14 as sensitive personal information, and CAC's 2019 Provisions on Cyber Protection of Children's Personal Information (China's COPPA-equivalent) requires parental/guardian consent for handling children's data; a CAC directive issued 28 December 2025 further requires companies collecting minors' personal information to complete compliance audits and file supporting materials with local CAC offices by 31 January 2026.observed 2026-08-03
- Uncertain[OneTrust DataGuidance](https://www.dataguidance.com/sites/default/files/gdpr_v_pipl_.pdf) — PIPL permits close relatives of a deceased individual to exercise that individual's data protection rights, but no equivalent statutory protection specific to living dependent adults (e.g., elderly or mentally incapacitated persons) was identified.observed 2026-08-03