The Cyberspace Administration of China ("CAC") recently issued the Measures for Cybersecurity Review (Revised Draft for Comment) (the "Draft for Comment") to solicit public comments by July 25, 2021.

The Draft for Comment specifies that operators who procure any online product and service shall make a pre-judgement of the risks to national security brought by the use of such product or service. If the national security is affected or may be affected, operators shall declare to the Office of Cybersecurity Review for cybersecurity review. Operators that possess more than one million items of personal information shall be subject to cybersecurity review when listing abroad. Meanwhile, the Draft for Comment clearly stipulates that cybersecurity review shall focus on the possible national security risks that may be caused by procurement activities, data processing activities and listing abroad, with factors in seven areas to be considered, such as "the risk that any key information infrastructure is illegally controlled, disturbed or destroyed after the product and service is used."

(Source: Cyberspace Administration of China)