JC Master Legal News Issue 1101

Key Takeaways for This Issue
The China Securities Regulatory Commission convened a symposium on the rule of law in the capital market.
On February 27, Wu Qing, Secretary of the CPC Committee and Chairman of the China Securities Regulatory Commission, chaired a symposium on the rule of law in the capital market, during which he solicited views and suggestions on improving the capital market’s foundational institutional framework and strengthening legal safeguards. Officials from the Legislative Affairs Commission of the Standing Committee of the National People’s Congress, the Supreme People’s Court, the Supreme People’s Procuratorate, the Ministry of Public Security, and the Ministry of Justice, along with selected experts, scholars, and lawyer representatives, attended the meeting.
The State Administration for Market Regulation has released a summary of its 2023 antitrust work.
On February 29, the official WeChat account of the State Administration for Market Regulation released an infographic summarizing its 2023 antitrust work.
China Research Center for New Forms of Employment: Among blue-collar workers, delivery riders and two other occupations have seen the fastest wage growth.
The China Research Center for New Forms of Employment has released the “2023 Report on Employment Among China’s Blue-Collar Workforce.”
The Law on the Protection of State Secrets has been revised and adopted, adding a dedicated provision on the confidentiality review of information disclosure.
On February 27, the Eighth Meeting of the Standing Committee of the 14th National People’s Congress revised and adopted the Law of the People’s Republic of China on Guarding State Secrets, which will take effect on May 1, 2024.
Finance & Capital Markets
The China Securities Regulatory Commission convened a symposium on the rule of law in the capital market.
On February 27, Wu Qing, Secretary of the CPC Committee and Chairman of the China Securities Regulatory Commission, chaired a symposium on the rule of law in the capital market, during which he solicited views and suggestions on improving the capital market’s foundational institutional framework and strengthening legal safeguards. Officials from the Legislative Affairs Commission of the Standing Committee of the National People’s Congress, the Supreme People’s Court, the Supreme People’s Procuratorate, the Ministry of Public Security, and the Ministry of Justice, along with selected experts, scholars, and lawyer representatives, attended the meeting.

At the symposium, participants spoke enthusiastically, fully endorsing the groundbreaking progress made in recent years in strengthening the rule of law in the capital market and offering suggestions on the next steps and priority measures. They agreed that to ensure the sound development of the capital market, it is essential to stay committed to market‑oriented and law‑based reform, accelerate legislative and regulatory updates across key areas—including oversight of listed companies, securities offices, mutual funds, and bonds—promptly assess and refine business rules, and establish institutional safeguards for good governance and sound regulation. Furthermore, it is crucial to improve China’s distinctive enforcement and judicial system for securities and futures matters, optimize the coordination between administrative and criminal enforcement, strengthen efficient collaboration among enforcement and judicial authorities, and intensify comprehensive accountability—administrative, civil, and criminal—to comprehensively enhance the effectiveness of a “zero‑tolerance” enforcement approach. In addition, efforts should be stepped up to implement civil compensation and redress mechanisms, issue judicial interpretations on civil liability for insider trading and market manipulation, expand the use of representative litigation, and make full use of the commitment‑based settlement mechanism. Targeted accountability must be applied to the principal perpetrators of illegal and criminal conduct, with vigorous efforts to recover illicit gains and mitigate losses, thereby effectively protecting the legitimate rights and interests of investors, particularly small and medium‑sized investors.

Wu Qing expressed his heartfelt gratitude to all for their longstanding strong support of the CSRC’s work. He emphasized that capital markets are subject to extremely high regulatory standards, and that a thriving market depends on the rule of law. The CSRC will carefully study and incorporate the views and suggestions put forward by the participants, and, in collaboration with relevant parties, work to expand the supply of legal frameworks, enhance enforcement effectiveness, and strengthen judicial safeguards, thereby better leveraging the rule of law to lay a solid foundation, stabilize market expectations, and deliver long-term benefits for the high-quality development of the capital market.

Relevant officials in charge at the China Securities Regulatory Commission, along with heads of pertinent departments and bureaus, attended the symposium.

The Shenzhen Stock Exchange convened a symposium for listed companies.
On February 28, the Shenzhen Stock Exchange convened a symposium with listed companies to gain insights into the business and industry landscape, while soliciting broad input on strengthening the capital market and the Exchange’s development, accelerating the emergence of new‑type productive forces, and promoting high‑quality economic growth. Sha Yan, Secretary of the Party Committee and Director of the Shenzhen Stock Exchange, attended and addressed the meeting, and eight chairpersons of listed companies took part in the discussion.

This gathering brought together leading companies from both foundational industries and emerging sectors, spanning advanced manufacturing, the digital economy, green and low‑carbon development, biopharmaceuticals, consumer retail, and other fields. The chairpersons of these companies shared insights into their businesses and industry trends, outlined strategies for enhancing corporate quality and improving investment returns, and offered valuable recommendations on fostering new‑type productive forces, advancing high‑quality development, and strengthening capital market infrastructure. Participants agreed that listed companies are a key driver of economic growth and should remain committed to technological innovation and integrity, continuously bolster core competitiveness, accelerate the development of new‑type productive forces, sustainably create investment value, and deliver greater returns to investors. They also recommended reinforcing end‑to‑end regulatory oversight of listed companies to fundamentally elevate their quality, rigorously control market access, crack down on egregious violations such as financial fraud, and promptly delist underperforming issuers. Furthermore, they called for ongoing improvements to institutional frameworks, encouraging greater inflows of medium- and long‑term capital, better leveraging market functions, and supporting high‑quality development.

Officials from the Shenzhen Stock Exchange listened carefully to the remarks of the chairpersons of the participating companies and expressed their gratitude for the strong support and valuable suggestions they have offered. The officials stated that the Exchange will earnestly implement the spirit of the Central Financial Work Conference and the State Council Executive Meeting, and, in accordance with the unified deployment of the China Securities Regulatory Commission, officely uphold the principle of putting investors first. Guided by the overarching theme of “strict regulation, risk prevention, and development promotion,” the Exchange will continue to strengthen full‑process oversight, resolutely investigate and address illegal and non‑compliant conduct, and foster the sound and sustainable development of listed companies. By better fulfilling its role as a key hub and platform, the Exchange will focus on advancing the five major tasks in the financial sector, enhancing the quality and investment value of listed companies, and accelerating the emergence of new‑type productive forces. The Shenzhen Stock Exchange will carefully study and incorporate the opinions and recommendations put forward by the participants, striving to deliver work that is solid, refined, and meticulous, further building consensus and harnessing collective strength to support the high‑quality development of the capital market.

Spokesperson of the China Securities Regulatory Commission Answers Questions from Journalists on Matters Related to Private Fund DMA Business
Q: Recently, some media reports have indicated that private equity funds are tightening their DMA business. What is the CSRC’s assessment of this?
A: Delta‑neutral asset management (DMA) is a market‑neutral strategy executed between private equity funds and securities offices. Under this arrangement, the private equity fund takes long positions in a basket of stocks while simultaneously using stock index futures for hedging, thereby capturing the excess returns generated by its stock‑selection process after hedging. Earlier, due to strategic considerations, some private equity funds experienced partial net‑value drawdowns amid market volatility. In response, securities offices and private equity funds proactively strengthened risk controls, steadily reducing leverage and scaling down their positions, which helped to mitigate risks to a certain extent. According to data from the China Securities Institutional Quotation System Co., Ltd., since the market reopened after the Spring Festival, the scale of DMA business has been declining steadily, with average daily trading volume accounting for approximately 3% of total market turnover. The steady deleveraging of DMA activities contributes to enhanced market risk management and supports the stable and healthy functioning of the market.
Going forward, the China Securities Regulatory Commission will continue to strengthen oversight and refine regulatory frameworks for over-the-counter derivatives businesses such as DMA, guide the industry in managing business scale and leverage, rigorously crack down on illegal and non-compliant activities, and ensure the stable functioning of the market.

Spokesperson of the China Securities Regulatory Commission Answers Questions from the Press on Disciplinary Measures Imposed by the China Financial Futures Exchange
Q: Recently, the China Financial Futures Exchange imposed disciplinary measures on a private fund management company and its de facto controller for failing to file reports as required regarding accounts under their de facto control and for engaging in high-frequency trading that exceeded position limits on stock index futures. What is the CSRC’s comment on this?
A: Recently, in accordance with applicable regulations, the China Financial Futures Exchange has imposed regulatory measures on relevant clients for violations of rules governing the management of accounts under actual control in the futures market. This action is part of the exchange’s efforts to fulfill its regulatory duties. The China Securities Regulatory Commission has consistently maintained a stringent regulatory stance, guiding stock exchanges and the China Financial Futures Exchange to strengthen coordination between spot and futures market oversight, conduct penetrating supervision of all types of trading activities—including high-frequency trading—and rigorously crack down on market misconduct in accordance with laws and regulations. Moving forward, the CSRC will continue to thoroughly implement the spirit of the Central Financial Work Conference, comprehensively enhance regulatory oversight, and ensure the stable and sound functioning of the market.

Has the IPO been retroactively investigated for the past 10 years? The CSRC responds.
On February 23, the China Securities Regulatory Commission held a press conference to address the recently widely discussed issue of “requiring IPOs to be retroactively investigated over the past 10 years.”
Yan Bojin, Chief Risk Officer and Director-General of the Issuance Department of the China Securities Regulatory Commission, stated that preventing and cracking down on financial fraud and fraudulent issuance is an ongoing effort. At present, there are no plans to conduct retrospective reviews of IPOs going back ten years; such reports in the media reflect investors’ growing concern about the quality of listed companies. In our oversight of the issuance and listing process, we are continuously strengthening end-to-end scrutiny, rigorously reviewing cases and imposing severe penalties for financial fraud and fraudulent issuance. The CSRC will also substantially increase the proportion of on-site inspections of companies seeking to go public, thereby addressing investor concerns by enhancing the overall quality of listed offices.

CSRC: Closely monitor egregious practices such as listed companies’ misuse of accounting policies to manipulate earnings.
On February 23, the China Securities Regulatory Commission (CSRC) held a press conference, during which Mr. Li Ming, Chief Inspector and Director of the Inspection Bureau, outlined the measures the CSRC will take to intensify its crackdown on illegal practices such as fraudulent issuance and financial fraud by listed companies.
Li Ming stated that the CSRC will closely monitor egregious practices such as listed companies’ abusive use of accounting policies to manipulate earnings, ensuring that fraudsters cannot “pull the wool over investors’ eyes” or slip through the cracks. The regulator will also strengthen end-to-end oversight and enforcement, rigorously vetting market entrants under a “declare and assume responsibility” principle, while ensuring a smooth exit process by resolutely weeding out companies engaged in serious violations. With respect to misconduct by the “key few”—including controlling shareholders, directors, supervisors, and senior executives—such as unauthorized appropriation of funds or misuse of guarantees, the CSRC will deploy a comprehensive set of measures: imposing severe penalties, conducting thorough investigations and seeking recovery, mandating corrective actions within specified deadlines, and referring cases to public security authorities, thereby leaving violators with nothing—neither their reputation nor their assets. Furthermore, for securities service intermediaries, the CSRC will adhere to a “dual‑investigation” approach, urging and warning these gatekeepers to fully assume their duties and responsibilities.

The Ministry of Finance will issue RMB 12 billion in government bonds in Hong Kong in March.
On February 28, the Ministry of Finance announced on its website that it will issue the first tranche of 2024 RMB-denominated government bonds in the Hong Kong Special Administrative Region on March 13, with a total issuance size of RMB 12 billion. Detailed issuance arrangements will be published through the Hong Kong Monetary Authority’s Central Moneymarkets Unit (CMU).

Shanghai will launch an action plan to enhance the ESG capabilities of foreign-invested enterprises.
On February 26, the Shanghai Municipal Government held an executive meeting to accelerate the establishment of a product carbon‑footprint management system, build a green and low‑carbon supply chain, strengthen the ESG capabilities of foreign‑related enterprises, and continue fostering world‑class arbitration institutions.
The meeting approved in principle the “Three-Year Action Plan for Accelerating the Enhancement of Environmental, Social, and Governance (ESG) Capabilities among Foreign‑Related Enterprises in This Municipality (2024–2026)” and the “Action Plan on Further Strengthening Capacity Building and Accelerating the Development of World‑Class Arbitration Institutions.” It was decided to give priority to including enterprises with strong ESG disclosure and high‑quality ratings within the scope of policy support for credit, foreign trade, consumption, and other areas. The meeting also proposed establishing an accounting and certification system aligned with international standards, promoting the adoption of international rules while facilitating the global outreach of domestic certification services. Additionally, efforts will be expedited to develop domestic standards for the measurement and accounting of product carbon footprints, helping foreign‑trade enterprises achieve transparency, traceability, and verifiability of their carbon footprints, and encouraging key sectors such as steel, chemicals, automotive, and electronics to take the lead in implementing carbon‑footprint accounting and management.

Commercial & Corporate
The CPC Central Committee: Continue to rectify formalism and bureaucratism, and address issues such as falsification of statistical data and the practice of imposing increasingly stringent targets at every level.
On February 28, the Chinese Government Website published the “Opinions of the General Office of the CPC Central Committee on Consolidating and Expanding the Achievements of the Thematic Education Campaign to Study and Implement Xi Jinping Thought on Socialism with Chinese Characteristics for a New Era.”
The “Opinions” comprise 15 provisions across four key areas, clearly stipulating the need to persistently address formalism and bureaucratism; to continuously rectify issues such as paying lip service to the CPC Central Committee’s decisions and deployments while falling short in implementation, pursuing departmental self-interest, and engaging in superficiality; to deepen efforts to correct problems like half‑finished projects, vanity projects, prestige‑driven initiatives, statistical falsification, and malpractices in grassroots governance; to tackle persistent problems such as oversimplified policy enforcement, one‑size‑fits‑all approaches, and escalating requirements at each administrative level; to strengthen oversight and inspection of the implementation of policies aimed at curbing formalism and alleviating burdens on the grassroots; to closely monitor hidden, cleverly disguised “new image projects” and other chronic issues that impose undue burdens on the grassroots; and to adopt robust measures to resolve pressing problems such as “small horses pulling heavy carriages,” thereby empowering the grassroots and reducing their burdens.

The State Administration for Market Regulation has released a summary of its 2023 antitrust work.
On February 29, the official WeChat account of the State Administration for Market Regulation released an infographic summarizing its 2023 antitrust work.
The State Administration for Market Regulation summarized its work in five key areas for 2023. First, it strengthened antitrust oversight and enforcement in priority sectors, continuously improving the market environment for fair competition. In 2023, a total of 27 cases involving monopoly agreements and abuse of dominant market positions were investigated and adjudicated, with fines and confiscations amounting to RMB 2.163 billion. Second, it rigorously conducted reviews of business concentration, fostering industrial development and safeguarding economic security. In 2023, restrictive conditions were imposed on four business‑concentration cases, and documents such as the “Antitrust Compliance Guidelines for Business Concentration” were issued. Third, it deepened the implementation of fair‑competition policies, steadily enhancing the effectiveness of fair‑competition governance. Fourth, it accelerated the improvement of the antitrust legal framework, further strengthening institutional safeguards for fair competition. Fifth, it intensified international cooperation and exchanges in the field of antitrust, further advancing and expanding institution‑based openness in the competition arena.

The Ministry of Finance has issued a document to further enhance the convenience of accessing and using government procurement information.
On February 26, the Ministry of Finance’s website published the “Notice on Further Enhancing the Convenience of Accessing and Utilizing Government Procurement Information.”
The Notice clarifies that, effective April 1, 2024, local sub‑sites of the China Government Procurement Website shall transmit all types of announcements and public notices for procurement projects within their respective regions—including those below RMB 5 million—to the central main site of the China Government Procurement Website for publication. The central main site will provide a “one‑stop” query service for nationwide government procurement project information. Furthermore, the central main site will establish a data‑sharing interface for registration information of government procurement agencies; starting April 1, 2024, local sub‑sites may access, via this interface, the registration details of government procurement agencies registered on the central main site. In addition, the central main site will launch a dedicated “Data Standards and Specifications” section to publish relevant data‑interface specifications.

The Ministry of Housing and Urban–Rural Development has issued a document requiring that statistical work for urban and rural development in 2024 be carried out effectively.
On February 29, the website of the Ministry of Housing and Urban–Rural Development released the “Notice on Doing a Good Job in Statistical Work for Urban and Rural Construction in 2024.”
The Notice clarifies that the annual statistical report on urban and rural development is divided into two parts: the Urban (County‑Town) Development Statistical Report and the Village and Town Development Statistical Report. The Urban (County‑Town) Development Statistical Report covers the following areas: population and construction land, public utility prices and standards, fixed‑asset investment in municipal infrastructure, water supply, water conservation, gas supply, centralized heating, rail transit, roads and bridges, drainage and wastewater treatment, landscape greening, environmental sanitation, historic and cultural districts, and municipal safety. For the 2023 Statistical Report on the Service Sector, the scope of coverage includes legal entities engaged in public facilities management with annual operating revenues of RMB 5 million or more that apply the enterprise accounting system, as well as those applying the administrative and institutional accounting system.

The Ministry of Housing and Urban–Rural Development has released the English versions of four engineering construction standards, including the “Seismic Design Standard for Hydraulic Structures.”
On February 29, the website of the Ministry of Housing and Urban–Rural Development published the “Notice on the Release of English Versions of Four Engineering Construction Standards, Including the ‘Seismic Design Standard for Hydraulic Structures.’”
The English-language versions of the engineering construction standards released in this batch primarily include the “Seismic Design Standard for Hydraulic Structures,” the “Safety Standards for Small Hydropower Station Construction,” the “River Flow Measurement Specifications,” and the “Technical Standard for Water-Saving Irrigation Engineering.”

The National Railway Administration plans to issue the “Administrative Measures for Survey and Design of Railway Construction Projects.”
On February 27, the website of the National Railway Administration published the “Notice on Soliciting Public Comments on the ‘Administrative Measures for Survey and Design of Railway Construction Projects (Draft for Comments)’,” with a deadline for submitting feedback set for March 28.
The Measures comprise ten chapters and fifty-eight articles, explicitly prohibiting survey and design entities for construction projects from undertaking railway engineering survey and design work beyond the scope authorized by their qualification level or in the name of another such entity; they also prohibit these entities from permitting other entities or individuals to undertake such work in their own name. Furthermore, the contracting party may not award railway engineering survey and design contracts to entities that do not possess the requisite qualifications.

The National Healthcare Security Administration Answers Questions Regarding 26 Untrustworthy Pharmaceutical Enterprises.
Recently, according to the National Healthcare Security Administration, as of December 31, 2023, 26 pharmaceutical companies have been designated as having engaged in “particularly serious” or “serious” breaches of trust.
An official from the National Healthcare Security Administration stated that, among 26 pharmaceutical companies, 25 were found to have engaged in commercial bribery, such as offering kickbacks and other improper benefits. For example, Zunyi Baiyi Pharmaceutical Co., Ltd. provided kickbacks and other “benefits” totaling RMB 3.5516 million to a county people’s hospital. Meanwhile, North China Pharmaceutical Group Corporation was penalized for failing to honor procurement contracts and for not supplying the winning bid products as agreed, thereby severely disrupting local clinical drug availability. Specifically, pharmaceutical enterprises deemed to have committed “serious” breaches of trust will face stricter sanctions, including suspension of their eligibility to list, bid for, or distribute the implicated products. Enterprises with “particularly serious” breaches of trust will be subject to even more severe measures, such as the suspension of all their drugs and medical consumables from being listed, bid for, or distributed in the province where the violation occurred.

Beijing cyber police have announced five cases of penalties for failing to fulfill cybersecurity protection obligations.
Recently, the official WeChat account of the Cybersecurity Bureau of the Ministry of Public Security published five cases of administrative penalties imposed by the Beijing Municipal Public Security Bureau’s cybersecurity authorities for failure to fulfill cybersecurity protection obligations.
In Case One, illegal gambling-related content was found on a website operated by a technology information service limited liability company in Beijing. The company’s official website consisted of static pages, and the server involved was a virtual server; users could access the static files without requiring any authentication. On November 12, 2023, an unauthorized individual gained access to the company’s server and modified the files to display gambling‑related information. Investigation revealed that, after the website was brought online, the system had not been registered with the public security authorities for cybersecurity classification protection, and a vulnerability scan had last been conducted six months earlier. The company failed to fulfill its cybersecurity obligations and did not implement technical measures to prevent computer viruses or network intrusions. Accordingly, the Dongcheng Branch of the Beijing Municipal Public Security Bureau ordered the company to make rectifications and issued a warning in accordance with the law.

China Research Center for New Forms of Employment: Among blue-collar workers, delivery riders and two other occupations have seen the fastest wage growth.
The China Research Center for New Forms of Employment has released the “2023 Report on Employment Among China’s Blue-Collar Workforce.”
The report shows that blue-collar workers in the service sector outperform their counterparts in manufacturing and the construction industry across these dimensions. In particular, new‑type blue-collar workers who rely on digital platforms—such as food delivery riders and ride-hailing drivers—demonstrate especially strong performance. Take food delivery riders as an example: their compensation ranks among the highest among blue-collar occupations, and they also boast the highest on-time payment rate. Meanwhile, food delivery riders, ride-hailing drivers, and couriers have emerged as the three fastest‑growing occupational groups in terms of wages within the blue-collar workforce.

Shanghai: Will ensure the creation of more than 550,000 new jobs and keep the unemployment rate below 5%.
On February 28, the Shanghai Municipal Government convened the 2024 Work Conference on Human Resources and Social Security and the Meeting on Employment Support for Key Enterprises, during which plans and arrangements were made for the year’s key priorities.
In 2024, Shanghai will place greater emphasis on employment‑first policies, ensuring that more than 550,000 new jobs are created throughout the year and keeping the surveyed urban unemployment rate below 5%. The city will launch the “Happy Work in Shanghai Plus” initiative to attract more workers, particularly young people, to seek employment and start businesses in Shanghai. It will also provide robust support and assistance to key groups, including college graduates, while fully implementing targeted services and safeguarding the rights and interests of those in flexible employment. Furthermore, Shanghai will comprehensively strengthen labor‑supply assurance for priority enterprises, offering precise job‑matching services, and establish 350 community employment service stations within “15‑minute employment service circles,” along with a number of comprehensive, regional, and industry‑specific gig‑work markets.

A member of the National Committee of the Chinese People’s Political Consultative Conference has proposed enshrining the right to offline rest in law, thereby raising the legal costs for companies engaging in covert overtime work.
With this year’s National People’s Congress and Chinese People’s Political Consultative Conference just around the corner, Lü Guoquan, a member of the National Committee of the CPPCC and Director of the General Office of the All-China Federation of Trade Unions, has proposed in his “Proposal on Safeguarding Workers’ Right to Offline Rest” that top-level design should be strengthened and that the right to offline rest be enshrined in labor legislation.
Lü Guoquan recommends revising standard working hours and clearly defining online overtime and corresponding compensatory time off. He also calls for strengthening research and standardization of labor‑related benchmarks—covering wages, working hours, rest periods, and leave—in the context of the digital economy, and integrating guarantees on working‑hour standards into the broader labor protection framework. Furthermore, he advocates delineating the boundaries between on‑site and remote work, and establishing institutional arrangements to set time limits for positions that rely on digital platforms, where working hours are variable and workloads are often intense.

The Law on the Protection of State Secrets has been revised and adopted, adding a dedicated provision on the confidentiality review of information disclosure.
On February 27, the Eighth Meeting of the Standing Committee of the 14th National People’s Congress revised and adopted the Law of the People’s Republic of China on Guarding State Secrets, which will take effect on May 1, 2024.
Following its revision, the Law on Protecting State Secrets comprises six chapters and sixty-five articles. It enshrines the Party’s leadership over secrecy work in law, focuses on the management of confidentiality in key regions, priority areas, and among personnel handling classified information, and refines the corresponding administrative systems, thereby further enhancing confidentiality measures. The revised law introduces new provisions on full‑process management of classified information systems and risk assessment, and revises and innovates management mechanisms. It also clarifies that the determination of the scope of classified matters shall adhere to the principles of necessity and reasonableness, changes the periodic review of state secrets to an annual review, urges government organs and institutions to promptly review already designated state secrets, promotes timely declassification, and adds specific provisions on the confidentiality review of information disclosure, among other enhancements.

Two departments have issued the 2024 edition of the National Basic Catalogue of Public Credit Information and the Basic List of Measures for Punishing Dishonesty.
On February 28, the website of the National Development and Reform Commission published the “Notice on Issuing the National Basic Catalogue of Public Credit Information (2024 Edition) and the National Basic List of Measures for Punishing Dishonesty (2024 Edition).”
The “National Basic Catalogue of Public Credit Information (2024 Edition)” encompasses 13 categories of public credit information, including judicial judgments and enforcement records, information on the list (status) of business (activity) anomalies, information on lists of seriously untrustworthy entities, contract performance data, information on credit commitments and their fulfillment, and intellectual property-related data, among others. The “National Basic List of Measures for Punishing Dishonesty (2024 Edition)” categorizes punitive measures into three types—measures that, in accordance with laws and regulations, reduce the rights or increase the obligations of credit subjects; relevant administrative measures implemented by public administration agencies as required for the performance of their duties; and measures independently adopted by organizations other than public administration agencies—totaling 14 items.

Two departments have jointly issued guiding opinions to strengthen the development of grid peak‑shaving and energy storage capabilities, as well as intelligent dispatching.
On February 27, the National Development and Reform Commission’s website published the “Guiding Opinions on Strengthening the Development of Grid Peak-Shaving and Energy Storage Capabilities and Intelligent Dispatching.”
The “Guiding Opinions” prioritize four key areas of work. First, strengthen peak‑shaving capacity: enhance the peak‑shaving capabilities of supporting power sources; coordinate efforts to boost the peak‑shaving capacity of renewable energy; significantly improve the grid’s ability to optimally allocate renewable resources; and tap the demand‑side potential for peak‑shaving. Second, advance energy storage capacity: plan and develop pumped‑storage hydropower stations; promote the deployment of new‑type energy storage on the supply side; optimize the scale and spatial distribution of new‑type energy storage in transmission and distribution; foster user‑side energy storage; and encourage the diversified and coordinated development of innovative energy‑storage technologies. Third, bolster intelligent dispatching capabilities: build next‑generation power‑dispatching support systems; enhance the cross‑provincial and cross‑regional coordination and scheduling of large power grids; refine operational mechanisms for dispatching in modern distribution networks; and explore coordinated dispatching frameworks that integrate multiple energy sources and align generation, grid, load, and storage. Fourth, reinforce market mechanisms and policy support.

Ministry of Housing and Urban–Rural Development: Ensure the effective preparation of housing development plans and annual implementation schedules.
On February 27, the website of the Ministry of Housing and Urban–Rural Development released the “Notice on Effectively Carrying Out the Preparation of Housing Development Plans and Annual Plans.”
The Notice requires all cities to prioritize government-led efforts in meeting the rigid housing needs of wage‑earning households, while relying on the market to address residents’ diverse and upgrading housing demands. Cities are to formulate annual housing development plans for 2024 and 2025 in a scientifically sound manner, comprehensively taking into account local economic and social development, demographic trends, industrial layout, and housing supply‑and‑demand dynamics. Drawing on the potential supply of existing housing stock and land, they should also proactively plan for housing development from 2026 to 2030. Furthermore, the construction of affordable housing must be incorporated as a key component of these housing development plans, with clear and well‑grounded targets set for affordable housing development.

The Ministry of Transport has issued the Measures for the Administration of Standards in the Transportation Industry.
On February 27, the website of the Ministry of Transport published the “Notice on Issuing the Measures for the Administration of Standards in the Transportation Industry.”
The Measures comprise six chapters and forty-one articles, covering general provisions, project initiation, organization and drafting, approval and publication, implementation and supervision, and supplementary provisions. They set forth requirements regarding the standards system, the solicitation of industry‑standard project proposals, eligibility criteria, project‑approval evaluation, project completion timelines, as well as the management of project adjustments and extensions. The Measures stipulate that the typical completion period for industry‑standard projects shall not exceed 18 months, and they establish requirements for approval, numbering, publication, printing, filing and public disclosure, archiving, expedited procedures, and amendment sheets.

The Ministry of Industry and Information Technology has issued a three-year plan to enhance data security capabilities in the industrial sector.
On February 26, the website of the Ministry of Industry and Information Technology released the “Notice on Issuing the Implementation Plan for Enhancing Data Security Capabilities in the Industrial Sector (2024–2026).”
The Implementation Plan sets forth 11 key tasks centered on enhancing three core capabilities: data protection for industrial enterprises, data security oversight, and industrial support for data security. It underscores the need to enforce principal responsibility, guiding enterprises handling critical data to establish and improve management systems, identify and file critical data, implement tiered protection measures, conduct regular risk assessments, and carry out risk‑event monitoring and emergency response. The plan aims to strengthen data security management at key enterprises, bolster risk prevention and control, and advance the development of data‑security technologies and solutions. Moving forward, the Ministry of Industry and Information Technology will foster coordinated efforts among government, industry, academia, research institutions, and end users to enhance the industrial support capacity for data security, expand the supply of technological products and services, and promote application deployment and the alignment of supply and demand.

Beijing plans to introduce new regulations on escrow of housing rental deposits and rent supervision.
On February 27, the Beijing Municipal Government website published an announcement soliciting public comments on the “Interim Measures for the Custody of Housing Rental Deposits and the Supervision of Rents in Beijing (Draft for Public Comment),” with a deadline for submitting feedback set for March 5.
The Measures consist of five chapters and twenty-one articles, stipulating that deposits collected by housing‑rental enterprises shall be held in a third‑party deposit escrow account opened with the Municipal Housing Funds Management Center. If the amount of rent collected by a housing‑rental enterprise in a single payment exceeds three months’ rent, the portion exceeding that threshold shall be subject to regulatory oversight, with monthly rent payments transferred to the enterprise’s account. Within one business day after the expiration or termination of a housing‑rental contract, the enterprise shall submit its decision on the return of the deposit and any withheld rent, clearly indicating whether the deposit or rent will be retained and providing a detailed breakdown of any deductions. The Measures also provide that tenants may, by means of the contract registration number and other relevant information, inquire about the balance held in their escrow deposit and rent‑regulation accounts. Furthermore, where routine supervision reveals failure to comply with deposit‑escrow and rent‑regulation requirements or the presence of operational risks, disbursement of funds from the rent‑regulation account to the housing‑rental enterprise may be suspended.

Shenzhen Releases the 2024 Work Plan to Promote Automobile Exports
On February 26, the Shenzhen Municipal Bureau of Commerce published the “Shenzhen 2024 Work Plan for Promoting Automobile Exports” on its website.
The Work Plan outlines 24 specific measures across six key areas: increasing the production volume of export‑ready vehicle models at local automakers; expanding the number of high‑caliber entities engaged in used‑car exports; accelerating the efficiency of procedures for exporting used cars; enhancing transportation and logistics support for auto exports; and strengthening comprehensive ancillary services to bolster automotive export capabilities. The plan explicitly supports automakers in leveraging their Shenzhen manufacturing bases to produce export‑oriented models, boost export output, and promote coordinated collaboration between production and trade to tap overseas markets. It also aims to cultivate more than 20 capable, high‑level enterprises that meet the requisite criteria to obtain qualifications for used‑car export operations, assist companies in establishing used‑car export refurbishment and preparation centers, and advance the implementation of a “tax rebate upon entry into the bonded zone/warehouse” policy for vehicles exported from Shenzhen, among other initiatives.

Two departments have issued the “Guidelines for the Construction of Projects to Protect and Enhance Historic and Cultural Cities and Districts.”
On February 23, the website of the Ministry of Housing and Urban–Rural Development issued the “Notice on the Issuance of the ‘Guidelines for the Construction and Enhancement of Historic and Cultural Cities and Districts (Trial)’.”
The Guidelines clearly stipulate that, in principle, project development should encompass the following six categories, or a combination thereof: (1) architectural conservation, restoration, and adaptive reuse; (2) preservation, restoration, and enhancement of historic urban landscapes; (3) improvement of surrounding environmental amenities; (4) upgrading of essential infrastructure and disaster‑prevention facilities; (5) enhancement of public cultural facilities; and (6) implementation of necessary dynamic monitoring and smart‑city management systems.

National Energy Administration: Effectively Ensure Safety Management for the Resumption of Power Construction Projects
Recently, the website of the National Energy Administration published the “Notice on Effectively Ensuring Safety Management for the Resumption of Power Construction Projects.”
The Notice clarifies that the project owner shall assume full and primary responsibility for construction safety in power‑generation projects, and must take measures to prevent accident risks arising from a rush to resume work. Personnel who have not completed and passed the required safety training shall be prohibited from commencing work, and special‑operation personnel must hold valid certifications to perform their duties. Where construction progress is delayed for any reason, the project schedule shall be extended accordingly to ensure that the actual duration complies with established quota standards, thereby preventing unauthorized shortening of timelines and hasty, uncoordinated efforts to accelerate progress.

The Ministry of Industry and Information Technology has released exemplary cases of joint construction and sharing of telecommunications infrastructure for 2023.
The “List” comprises 50 exemplary cases, including “Joint Government–Enterprise Initiative for the Co‑construction and Sharing of a 4G/5G Private Network along the Liaocheng Section of the Jinan–Zhengzhou High-Speed Railway,” “5G Integrated Solution for Beilonghu Financial Island,” “Large-Scale Shared Spectrum Dual-Carrier Deployment for Ubiquitous Gigabit 5G,” “China Telecom Beijing’s ‘Dual‑Gigabit’ Network Co‑construction and Sharing Case,” and others.

Shanghai has issued the “Implementation Opinions on Systematically Promoting Sponge City Construction Across the Entire Municipality.”
On February 26, the Shanghai Municipal Government website published the “Notice on Issuing the Implementation Opinions on Systematically Advancing Sponge City Construction Across the Entire Municipality.”
The Implementation Opinions set forth the following key tasks: (1) refine the technical framework for sponge city planning; (2) strengthen regional ecological conservation and restoration; (3) build a resilient and secure urban river‑lake system; (4) improve the construction of urban drainage and flood‑prevention infrastructure; (5) advance sponge city projects across all areas; and (6) enhance capacity in the planning, construction, and management of sponge cities.

Beijing plans to issue the 2024 edition of the discretionary standards for administrative penalties in public security management.
On February 26, the Beijing Municipal Government website published the “Notice on Public Solicitation of Comments on the ‘Notice of the Beijing Municipal Public Security Bureau on Issuing the Discretionary Standards for Administrative Penalties in Public Security Management (2024 Edition)’ (Draft for Comments),” with a deadline for submitting feedback set for March 5.
The “Discretionary Standards” focus on the administrative penalty discretion criteria set forth in the “Beijing Municipal Regulations on Safety Management Along Railway Lines,” the “Work Safety Law,” and the “Labor Law.” Specifically, Article 28 of the “Beijing Municipal Regulations on Safety Management Along Railway Lines,” which pertains to the administrative penalty powers of public security organs, and Article 110 of the “Work Safety Law,” which likewise involves such powers, are subject to a two-tiered discretionary classification—“less serious circumstances” and “more serious circumstances.” Meanwhile, Article 96 of the “Labor Law,” which also concerns the administrative penalty powers of public security organs, is treated in accordance with the provisions of the “Notice of the Ministry of Public Security on Issuing the Revised ‘List of Names of Violations of Public Security Administrative Regulations and Related Opinions on Their Application,’” and is governed by Article 40, paragraphs 2 and 3, and Article 43, paragraph 1, of the “Law on Public Order Administration Penalties”; no separate standards have been formulated for this provision.

Shanghai has issued the “Key Work Priorities for Special Equipment Safety Supervision in Shanghai for 2024.”
On February 27, the Shanghai Municipal Market Supervision Administration website published the “Notice on Issuing the ‘Key Work Priorities for Special Equipment Safety Supervision in Shanghai in 2024.’”
The “Key Work Plan” comprises five areas and 18 specific measures, calling for strengthening enterprises’ principal responsibility, ensuring the fulfillment of industry‑specific supervisory duties, reinforcing local regulatory accountability, solidifying inspection and testing obligations, standardizing routine oversight and inspections, deepening targeted supervisory checks, implementing post‑certification follow‑up inspections, intensifying efforts to crack down on illegal activities and violations, comprehensively advancing smart‑regulation initiatives, bolstering credit‑based regulation, and continuously pushing forward regulatory reforms. In addition, it will formulate and issue normative documents such as the “Shanghai Municipal Approval Rules for Class B Special Equipment Inspection Agencies” and the “Shanghai Municipal Measures for the Administration of Smart Elevator Information.”

Zhejiang has put forward 18 measures to support the construction and development of Deqing, Zhejiang, as a national-level connected-vehicle pilot zone.
Recently, the Zhejiang Provincial Government website published the “Several Opinions on Supporting the High-Quality Development of the National-Level Connected Vehicle Pilot Zone (Deqing, Zhejiang).”
The “Several Opinions” comprise five key areas and eighteen specific measures, proposing the establishment of a science-and‑technology innovation system for the connected‑vehicle industry. It designates breakthroughs in critical connected‑vehicle technologies as priority projects under the province’s major science and technology programs, promotes intensive R&D efforts, and fosters deep collaboration among industry, academia, research institutions, and end-users. The document also supports and guides Deqing County in applying to establish a “Ten-Thousand-Mu, Hundred-Billion‑Yuan” new‑industry platform, focusing on Beidou‑based geospatial information, connected vehicles, and intelligent transportation equipment to build an innovative development platform for vehicle‑connected smart manufacturing. Additionally, it calls for advancing the construction of connected‑vehicle infrastructure, supporting the creation of a “Geoinformation Plus” industrial fund to establish diversified investment and financing mechanisms, and launching high‑precision map services for intelligent connected vehicles, while promoting data development and utilization in the connected‑vehicle sector to drive deeper applications.

State Council Executive Meeting: Examining Policy Measures to Further Attract and Utilize Foreign Investment
On February 23, Premier Li Qiang of the State Council presided over an executive meeting of the State Council, heard a report on the work of 2023 by State Council departments in handling proposals from deputies to the National People’s Congress and motions from members of the National Committee of the Chinese People’s Political Consultative Conference, and deliberated policy measures to attract and utilize foreign investment more vigorously.
The meeting emphasized that stabilizing foreign investment should be a key priority in this year’s economic work. It called for strengthening services and safeguards by expanding market access, optimizing a fair competitive environment, and facilitating the smooth flow of innovation‑related factors, thereby continuously fostering a world‑class business climate characterized by market orientation, rule of law, and internationalization. These efforts aim to bolster foreign investors’ confidence in operating in China and to elevate the quality and level of trade and investment cooperation.
The meeting reviewed and approved the “Opinions on Further Optimizing Payment Services and Enhancing Payment Convenience,” emphasizing the need to address payment-related challenges faced by elderly individuals, foreign nationals residing in China, and other vulnerable groups, while promoting the parallel development and mutual complementarity of diverse payment methods, including mobile payments, bank cards, and cash.
The meeting reviewed and approved the Draft Regulations on Water Conservation, the Draft Regulations on Ecological Protection Compensation, and the Draft Regulations for the Implementation of the Consumer Rights Protection Law of the People’s Republic of China.

Taxation
Joint Efforts by Eight National Departments to Combat Tax-Related Criminal and Illegal Activities
The推进 meeting was held in Beijing.
On February 27, the State Taxation Administration, the Ministry of Public Security, the Supreme People’s Court, the Supreme People’s Procuratorate, the People’s Bank of China, the General Administration of Customs, the State Administration for Market Regulation, and the State Administration of Foreign Exchange convened in Beijing a national joint conference to advance efforts to combat tax-related illegal and criminal activities. Guided by Xi Jinping Thought on Socialism with Chinese Characteristics for a New Era, the meeting earnestly implemented the decisions and arrangements of the CPC Central Committee and the State Council, reviewed the achievements of the joint campaign against tax-related offenses, and outlined key tasks for the next phase, with the aim of further fostering a law-based, fair business environment and better supporting high-quality economic and social development.
The meeting noted that in 2023, the mechanism for routinely combating tax-related illegal and criminal activities continued to improve, with inter‑departmental collaboration further expanded and deepened, thereby establishing a new, integrated framework that covers the entire chain—from administrative enforcement to criminal justice. Over the past year, eight government departments fully leveraged the joint enforcement mechanism, launching vigorous crackdowns on tax‑related offenses such as issuing false invoices and fraudulently obtaining tax refunds, resulting in stringent investigations and prosecutions that effectively deterred offenders and safeguarded both economic order and national tax security. In 2023, nationwide inspections were conducted on 174,000 enterprises suspected of issuing false invoices or committing tax fraud; in particular, serious measures were taken against illegal acts such as fraudulently claiming export tax rebates, recovering approximately RMB 16.6 billion in lost export tax refunds. At the same time, in support of the effective implementation of tax and fee preferential policies, targeted preventive and enforcement efforts were carried out to address key risks, averting losses of RMB 3.2 billion in state tax revenues and ensuring that policy benefits did not end up in the pockets of unlawful actors.
The meeting emphasized that all departments must adhere to Xi Jinping Thought on Socialism with Chinese Characteristics for a New Era as their guiding principle, continue to study and thoroughly grasp the spirit of General Secretary Xi Jinping’s important instructions and directives, and consciously uphold the political stance of officely safeguarding the “Two Establishments” and resolutely upholding the “Two Safeguards.” They should comprehensively implement the decisions and arrangements of the CPC Central Committee and the State Council, rely closely on the support of Party committees and governments at all levels, and maintain a clear understanding of the prevailing situation and tasks, their respective responsibilities and positioning, strategic approaches, and work requirements. Furthermore, they are to continuously deepen and refine the joint‑law‑enforcement mechanism, severely crack down on tax‑related illegal and criminal activities in accordance with the law, and fully leverage their functions in ensuring national tax security, maintaining economic order, and upholding social fairness and justice. By doing so, they will steadily enhance the quality and effectiveness of the eight‑department joint effort to combat tax‑related crimes, better foster a law‑based environment, better serve high‑quality development, and make new and greater contributions to advancing the modernization of China’s governance system and governance capacity.
The meeting was held via video link. Relevant officials from the eight departments attended and addressed the session at the main venue, while representatives from several grassroots-level agencies shared their experiences. Officials from the tax, public security, courts, procuratorates, People’s Bank of China, customs, market regulation, and foreign exchange management authorities in each province, as well as from the State Taxation Administration’s resident commissioner offices in various localities, participated in the meeting at their respective sub-venues.

Guangdong: Striving to prioritize the implementation of tax incentives, such as differentiated tax rates, to encourage venture capital offices to adopt a long-term investment approach.
On February 21, the website of the Guangdong Provincial People’s Government released the “Implementation Opinions on Accelerating the Deep Integration of Science and Technology with Finance to Support the Innovative Development of Technology-Based Enterprises,” outlining fifteen key areas of action.
The “Implementation Opinions” propose attracting venture capital institutions to develop in Guangdong. They call for strengthening publicity and practical guidance on tax preferential policies for venture capital, and for seeking national support to prioritize the implementation in Guangdong of tax incentives—such as differentiated tax rates—that encourage long-term investment by venture capital offices. Furthermore, they aim to enhance the facilitation of cross-border investment and financing in the science and technology sector. For overseas investors who invest in Guangdong‑based venture capital enterprises and high‑tech projects listed in the National Catalogue of Industries Encouraged for Foreign Investment through Qualified Foreign Limited Partners (QFLP), a fast‑track approval channel will be established.

The overall plan for the Shanghai Business Cooperation Zone has been unveiled, with management implemented in accordance with the policies governing comprehensive bonded zones.
On February 28, the Shanghai Municipal Government website released the “Overall Plan for the Construction of the Shanghai Eastern Hub International Business Cooperation Zone.” The plan comprises five key areas and seventeen specific measures, with the goal of achieving, by 2030, a region characterized by convenient cross-border exchanges, vibrant international business activities, a concentration of innovation‑related resources, leading professional service capabilities, and fully developed supporting infrastructure.
The Overall Plan proposes encouraging headquarters‑based enterprises, multinational corporations, and international institutions to conduct cross‑border business activities within the zone; expanding the coverage of point‑of‑sale (POS) terminals that accept foreign bank cards; and stipulating that goods entering or leaving the Business Cooperation Zone from overseas or from areas outside the zone shall be managed in accordance with the policies applicable to comprehensive bonded zones. Infrastructure materials required for the development of the Business Cooperation Zone, as well as equipment and instruments needed for its operations, will be subject to a list‑based management system: upon approval following prescribed procedures, they will be exempt from customs duties and import‑related taxes, while goods not included on the list will be taxed in accordance with relevant regulations. Furthermore, infrastructure materials and operational equipment and instruments imported into the zone from areas outside the zone, if they meet the conditions for tax rebates applicable to entry into comprehensive bonded zones, may qualify for tax refunds under the existing policies governing such zones.

Litigation & Arbitration
The Supreme People’s Court has released the first batch of 10 selected Q&A entries from the Legal Answers Website.
On February 29, the Supreme People’s Court website published a selection of Q&A entries from the “Fa Da Wang” platform (the first batch). Fa Da Wang is an information-sharing platform established by the Supreme People’s Court to provide judicial officers at all four levels nationwide with services for applying laws and policies, seeking advice on trial-related matters, and engaging in learning and exchange. Consultations are limited to issues of legal application and must not address specific cases; the responses provided are intended solely for educational, research, and reference purposes.
This batch of responses to inquiries comprises 10 items, primarily addressing issues such as the determination of labor relationships for online livestreaming sellers, child custody in divorce cases, the priority right of creditors to be repaid from assets held in margin trading and securities lending credit accounts, inflated valuations in corporate capital contributions, the treatment of company‑related assets in bankruptcy proceedings, debt settlement by way of property, and the abuse of official authority.

The Supreme People’s Procuratorate has launched the “Procuratorial Protection of People’s Livelihood” special campaign, outlining 11 key areas of action.
Recently, the Supreme People’s Procuratorate issued the “Implementation Plan for the Nationwide ‘Procuratorial Protection of People’s Livelihood’ Special Campaign,” deciding to launch this special campaign across all procuratorial organs nationwide from February to December 2024.
The Implementation Plan, focusing on key areas of public concern such as employment, food and drug safety, and social security, as well as priority groups including workers, consumers, and women, sets out 11 priority actions. It calls for further strengthening the protection of workers’ rights—particularly those in flexible and new forms of employment—carrying out targeted civil procuratorial supervision in the financial sector, handling real estate‑related disputes effectively, launching public interest litigation by the procuratorate to address food and drug safety issues in emerging online business models, conducting special supervisory efforts on food safety concerns in new business formats such as livestreaming e‑commerce, and intensifying judicial protection of citizens’ personal information, among other measures.

The People’s Courts Case Database has officially launched and been made publicly accessible, compiling and indexing 3,711 cases.
On February 27, the Supreme People’s Court held a press conference to announce the official launch and public access of the People’s Courts Case Database, which compiles authoritative guiding cases and reference cases that have been reviewed by the Supreme People’s Court as having demonstrative value for similar cases.
At present, the case database contains a total of 3,711 cases, achieving nearly complete coverage of common offenses and frequently occurring causes of action. It also includes a number of cases involving the protection of property rights and the rights of entrepreneurs in private enterprises, corporate compliance cases, and intellectual property protection cases. According to an official from the Supreme People’s Court, the China Judgments Online platform and the People’s Courts Case Database serve distinct purposes. During the development of the People’s Courts Case Database, efforts to make judicial documents publicly available will only be strengthened, not weakened, and, while further increasing transparency, measures will be refined to address issues such as the protection of rights and potential security risks arising from online publication.

The Supreme People’s Procuratorate has launched the “Prosecutorial Protection of Enterprises” special campaign, outlining 14 key measures.
The Supreme People’s Procuratorate recently issued the Work Plan for the “Procuratorial Protection of Enterprises” Special Campaign, deciding to launch the campaign from February to December 2024.
The Plan specifies that this special campaign will focus on 14 key measures, primarily targeting crimes that undermine fair competition and corruption within private enterprises, as well as overseeing and addressing breaches of fiduciary duty by company controllers and senior executives. It will also launch a targeted crackdown on “shell companies,” strengthen oversight of case filings involving business entities, exercise prudent restraint in the application of coercive measures, conduct specialized supervision over the enforcement of property‑related provisions in criminal judgments, and carry out legal oversight of the execution of such provisions in cases involving infringements upon the legitimate rights and interests of enterprises. Furthermore, it will enhance supervision of final civil judgments and enforcement proceedings related to businesses, intensify oversight of administrative litigation—particularly final administrative judgments and administrative violations—and undertake public interest litigation oversight. Efforts to handle complaints and appeals will be stepped up, while protection of property rights for private enterprises will be strengthened, and comprehensive prosecutorial functions in the field of intellectual property, along with compliance reforms for enterprises involved in legal proceedings, will be deepened.

The Shanghai Higher People’s Court has released the first batch of reference cases for 2024.
On February 29, the official WeChat account of the Shanghai Higher People’s Court released the first batch of reference cases for 2024, primarily focusing on internet-related matters.
This batch comprises five reference cases. In Reference Case No. 170, Li’s case of assisting in cybercrime activities, the Shanghai Higher People’s Court clarified that WeChat serves both payment‑settlement and communication‑transmission functions. Where an actor knowingly sells a WeChat account to another person who intends to use the information network to commit a crime, such conduct may be deemed “assistance” under the crime of assisting in cybercrime activities. However, if the WeChat account is sold or provided with the registrant’s consent or after the registrant has independently registered the account, this does not meet the criterion of “violating relevant state regulations” as stipulated in Article 253‑1 of the Criminal Law and therefore does not constitute the crime of infringing upon citizens’ personal information. Where the sale of a WeChat account constitutes the crime of assisting in cybercrime activities, the number of accounts involved may be determined using a holistic approach, but rebuttal evidence must be permitted.

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