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Notes from the Asia-Pacific region: AI, privacy and cyber enforcement in Greater China, Hong Kong
The past several weeks in Greater China have been packed, with significant artificial intelligence and data rules and guidelines released and adopted in both mainland China and Hong Kong. On 9 Sept., China's highest court — the Supreme People's Court — released the landmark opinions providing guidance to Chinese courts at all levels on handling AI-related cases.
Hong Kong’s new Guidance on protecting personal data privacy in agentic AI use
The PCPD’s new Guidance marks a regulatory milestone for agentic AI in Hong Kong. Published on 25 August 2026, this is the first guidance from the PCPD specifically addressing the privacy risks of autonomous AI systems. It sets out nine data-protection recommendations and a lifecycle security checklist, signalling heightened regulatory expectations for organisations deploying agentic AI. Organisations remain fully accountable for personal data processed by AI agents.
China proposes enhanced data protection rules for large-scale personal information handlers
On 7 August 2026, the Cyberspace Administration of China (CAC) published the Draft Provisions on Personal Information Protection for Large-Scale Personal Information Handlers (Draft Regulation) for public comment, with the consultation period closing on 7 September 2026. The Draft Regulation comes on the heels of the Provisions on Simplified Measures for Personal Information Protection for Small-Scale Personal Information Handlers, which will take effect on 1 September 2026 (Simplified Measures).
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