Bridging the Great Wall: China’s Evolving Cross-Border Data Flow Policies and Implications for Global Data Governance

Abstract

Despite the rapid expansion of the digital economy, the global regulatory framework for data flows remains fragmented, with countries adopting divergent approaches shaped by their own regulatory priorities. As a key player in the Internet economy, China’s approach to cross-border data flows (CBDF) not only defines its domestic digital landscape but also influences emerging global norms. This paper takes a comprehensive view of the evolution of China’s CBDF regime, examining its development through both domestic and international lenses. Domestically, China’s regulation of CBDF has evolved from a security-first approach to one that seeks to balance security with economic development. This paper examines the economic, political, and international drivers behind this shift. This paper also compares the approaches of China and the United States to CBDF, in light of the recent tightening of US restrictions, from both technical and geopolitical perspectives. At the technical level, recent policy trends in both countries reveal notable similarities. At the geopolitical level, however, the divergence between the two frameworks is not only significant but continues to widen. The paper concludes by examining the broader implications for global data governance and offering recommendations to bridge digital divides and promote a more inclusive international framework.