China drives digital transformation forward: new e‑document regulation

Effective 1 September 2026, the “Provisions on Promoting and Regulating the Application of Electronic Documents” (Provisions) will come into force in China. The Provisions were adopted by the Cyberspace Administration of China (CAC) and eight other central authorities, as well as the People’s Bank of China.

The goal of the Provisions is to promote digital processes, efficient logistics, and the digital currency (e-Yuan). This is to be achieved through the standardization of electronic documents, invoices, and certificates in accordance with various national laws, including the Law on Electronic Signatures, the Cybersecurity Law (CSL), the Data Security Law (DSL), and the Personal Information Protection Law (PIPL).

Key provisions of the guidelines

Scope of Application

The provisions serve as a framework for all activities related to electronic documents carried out in China. In particular, the trade, logistics, and financial sectors are encouraged to use and recognize electronic documents and the digital RMB. Among others, the following are mentioned:

• Bills of lading
• Sea, rail, air, and road waybills
• Documents for multimodal transport
• Warehouse receipts,
• Electronic cargo insurance policies.

Standards

The competent authorities must develop national standards for electronic documents, which should be done with the participation of industry associations and other stakeholders. Operators of electronic document systems are, for their part, encouraged to use these national standards.

Business rules

Operators of electronic document systems must, for their part, formulate appropriate business rules, verify the identity of users, and contractually regulate the rights and obligations regarding use with the users. Provided that data protection laws are observed, operators are also encouraged to provide cross-border services , e.g., in international trade and transport transactions.

Security

Institutions and individuals are encouraged to carry out the issuance, storage, modification, transfer, and pledging of electronic documents, etc., through reliable electronic document systems that must meet specific security and transparency criteria. Operators are encouraged to have the reliability of their systems certified.

Data Protection

If, for example, an electronic document system constitutes critical information infrastructure, the corresponding cybersecurity requirements in the CSL must also be met. If data from electronic documents is transmitted to users abroad, the rules on cross-border data transfer must be observed, unless explicit exceptions for cross-border trade and transport apply.

Supervision

The CAC, together with other authorities, is jointly responsible for formulating standards, norms, and administrative requirements and exercises relevant oversight.

Our assessment

The new regulations indicate that China aims to increase the use of digital documents. It remains to be seen exactly how this will be implemented in practice and what administrative and IT-related challenges this will pose for companies. But the establishment of national standards may enhance the efficiency and security of business processes and strengthen China’s role in global digital trade and transportation.

Those already operating in the Chinese market not only benefit from early standardization but may also secure competitive advantages by getting in early, should this digital document infrastructure spread beyond China.

Recommendations

To prepare for the expected changes, companies should conduct a data protection compliance review at an early stage. This involves verifying whether current processes, contracts, and technical measures comply with the requirements of the CSL, the DSL, and the PIPL, and making any necessary adjustments. In other words, becoming “fit for electronic documents” as quickly as possible.