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China

Last updated : January 29, 2026

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Digital ID Overview

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China’s new digital ID system was passed through new legislation known as the National Online Identity Authentication Public Service on 15 July 2025, following a year-long beta phase.[19] The digital ID, known as the ‘Internet ID’, enables Chinese residents to voluntarily enroll through a government app on NFC-enabled mobile phones.[20] To obtain the digital ID, individuals scan their legal identity document to verify their identity, then submit a facial scan, mobile phone number, and password.[21] The legal identity documents that can be used to register are the RIC; residence permits for Hong Kong, Macau and Taiwan; mainland travel permits for Hong Kong, Macau and Taiwan residents; foreign permanent residence ID card; and passports of overseas Chinese.[22] The Internet ID requires children aged 14 years and below to obtain parental or guardian consent, with the application submitted on their behalf, while for those aged between 14 and 18 may apply in their own name but only under the supervision of a parent or guardian.[23]

Upon registration, the app generates a ‘internet number’ and ‘internet certificate’ for Chinese residents that allows individuals to access social media platforms, government sites, and commercial platforms with their Internet ID.[24] The app centralizes the process and shifts identity verification from private companies to government agencies, allowing the government to track users’ activity across platforms, removing the anonymity of users, and restricts users who make statements deemed sensitive.[25] Researchers have raised concerns that this state-issued Internet ID, designed with ‘information security and fraud prevention’ in mind, could be used to further limit freedom of expression in digital spaces since it allows the government more control of online spaces.[26]

The internet ID for citizens and non-citizens with permanent residence status acts as a functional ID because it is used for identity verification purposes and to access public services platforms, commercial platforms, as well prominent online social media and commerce platforms such as We Chat, Xiaohongshu (RedNote), and TaoBao.[27] Although it is not mandatory to use the digital ID for citizens and non-citizens, the government is encouraging public services, private services, and general users to adopt it, with more than 80 mobile applications trialling the app during the testing phase in 2024.[28] According to Article 19, the platform has registered six million users who have activated the service and the app has provided authentication services more than 12.5 million times.[29] 

In terms of access to Internet ID for non-citizens, foreign residents who hold foreign permanent resident ID cards are eligible to register for Internet ID since it is linked to the physical registration cards.[30] However, stateless persons, refugees, asylum seekers, or other undocumented migrants who are unable to obtain essential legal identity documents such as the Medical Certificate of Birth and the residence identity cards are unable to access the Internet ID along with the public and private services linked to the digital ID.[31] Since China’s Internet ID is based on the physical residence identity cards which are available for citizens and foreign permanent residents, both IDs are not a marker of citizenship and function as a method of identity verification and provide access to services.

The government launched its national digital ID trial for 81 applications on 6 August 2024, one week after releasing its draft regulations for public comment.[32] The feedback period for the public to register for the digital ID as part of the beta testing was until 25 August 2024.[33] Critics have been skeptical of the testing and public feedback phase because posts on social media criticizing the digital ID plan were removed from Chinese platforms.[34] The Internet ID was developed by the Ministry of Public Security (MPS) and the Cyberspace Administration of China (CAC), showing no indication of any private sector involvement.[35]

Law

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Domestic law and policy

The main law regulating China’s digital ID system is the Measures on the Management of the National Online Identity Authentication Public Service, effective 15 July 2025 released by the CAC.[36] According to DataGuidance, the Measures require public service platforms to collect only necessary information, obtain consent, ensure data security, and store data in China, while internet platforms must provide equal services regardless of identity verification method and obtain separate consent for third-party data sharing.[37] The aim of the Measures is to promote the development of national public services for online identity authentication, protect the security of citizens’ identity information, and supporting the development of the digital economy, as stipulated in Article 1.[38]

According to Article 2 of the Measures, ‘internet number’ refers to an online identifier that corresponds to the identity information of a natural person, consisting of letters and numbers, and contains no plaintext identity information. Whereas, ‘internet certificate’ means an online identity authentication certificate that carries the online identifier and non-plaintext identity information of a natural person.[39]  China’s Internet ID can be defined as a combination of letters and digits that is encrypted and corresponds one-to-one with an individual’s ID number without containing the plaintext of such information, while the web certificate refers to an online identity authentication certificate that holds the Internet ID and the identification of an individual.[40] 

Penalties are imposed for violations of these key provisions on platforms’ use of digital ID service, including data handling, user notice and consent, and information security, under Article 14 of the Measures as well as other relevant cybersecurity and data protection laws.[41]

Data Protection

There are data protection safeguards within the Measures on the Management of the National Online Identity Authentication Public Service that mandates the ‘public service platform’ (the government run centralized online system that provides digital identity authentication services) to:

  • limit collection of ‘sensitive’ personal information,[42] including biometric data, to what is necessary, obtain informed notice and voluntary consent (Art. 9–11);
  • prohibit handling or sharing data without independent consent and restrict use to authentication purposes (Art. 9);
  • delete personal information in accordance with law or user request (Art. 9);
  • provide clear transparency on its data practices (Art. 11);
  • implement strong security, operational and data protection measures including domestic storage and incident response (Art. 12);
  • comply with the requirements related to the state management of encryption (Art.13);
  • comply with related data protection laws with sanctions for violations (Art. 14).[43]

According to DLA Piper, China does not have a single comprehensive data protection law. Instead, its legal framework is built on three key statutes: the Cybersecurity Law (CSL), the Data Security Law (DSL), and the Personal Information Protection Law (PIPL).[44] The CSL, the first law established in 2017 addressing cybersecurity and data protection, establishes broad obligations for network operators to protect network security and personal or important data, including requirements for data localization, security measures, and protection of critical information infrastructure across networks in China.[45] The DSL, taking effect in 2021, focuses on regulating all data processing, introducing data classification (important, core data), requiring data localization for critical data, and restricting cross-border transfers. The PIPL, also introduced in 2021, is the first comprehensive national privacy law that governs how personal information of individuals is collected, used, stored, and transferred, grants data subject rights, and imposes consent and compliance requirements on organizations processing such data.[46] The PIPL treats biometric data as sensitive personal information, requiring explicit and informed consent for its collection, with clear specification of purpose and adherence to proportionality.[47]

There are also provisions within these data protection laws that set the foundation for the government to develop digital ID systems. Article 62 of the PIPL grants the CAC the power to research, develop, and roll out digital identity verification technologies that are secure and convenient.[48] Article 24 of the CSL stipulates the State shall implement ‘network identity credibility strategy’ and support research secure and convenient digital identity verification technologies.[49]

Despite all the safeguards for protection of personal information guiding the Internet ID, the government has full access and control of all data collected because the Internet ID system and its identity verification services is developed and managed by government.[50] This raises major concerns around mass state surveillance, data centralization, and risks of government censorship and control of digital information.[51] The primary apprehension is that the system links all online activity to an individual’s real identity, enabling the government to track and monitor their digital trail.[52] Researchers studying internet freedom warned that with the state-led system capable of real-time monitoring and blocking of users’ access to any online platform, ‘the Internet ID becomes more than a surveillance tool, but an infrastructure of digital totalitarianism.[53] The reduction of anonymity in the digital ID system has led legal scholars and activists who criticized it online to face censorship and social media bans, underscoring the broader issue of state repression against dissenting voices.[54] The organizations, Article 19 and Chinese Human Rights Defenders warned that the digital ID system would intensify surveillance and reduce anonymity, increasing the risks of censorship, state retaliation and reprisals against already at-risk human rights defenders.[55] Human rights groups also warned that this digital ID model could inspire other authoritarian regimes to use digital identity tools to monitor people online.[56] 

International Commitments

The Republic of China has ratified several major human rights treaties including the 1951 Refugee Convention, ICESCR, ICERD, CRC, and CEDAW.[57] In its 2018 and 2023 concluding observations, the CERD and CEDAW Committees raised concerns that children born in China to women from North Korea are effectively prevented from birth registration due to the risk of refoulement or deportation, resulting in heightened risks of statelessness and denial of access to basic rights and services. The Committees recommended that China ensure birth registration and eligibility for nationality.[58] The CRC Committee [59] in 2013 also highlighted low birth registration rates in poor and remote areas of mainland China, linked to the household registration (hukou) system, noting how the numerous administrative requirements towards birth registration creates barriers to accessing legal identity. It recommended systemic reform to ensure universal birth registration.[60] The CRC Committee, in its General Comment No. 25 in 2021, also stated that digital systems should be created in a way that enable children to safely access essential digital public services and educational services without discrimination.[61]


On 26 June 2025, China adopted the Ministerial Declaration on a Decade of Action for Inclusive and Resilient Civil Registration and Vital Statistics in Asia and the Pacific, pledging commitments to universal access, gender equality, digital inclusion, and resilient civil registration and vital statistics systems.[62]  The Declaration commits to building secure digital public infrastructure that enables equitable access to services and entitlements, while ensuring that ‘vulnerable and digitally marginalized groups’ are not excluded.[63]

Designed to Include?

The Impact of Digital ID and Legal Identity on Citizenship and Nationality Rights

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China’s digital ID systems framework has neither contributed to nor reduced statelessness. However, in practice, it reinforces existing exclusions based on access to legal identity. Access to the Internet ID is contingent on possession of foundational legal identity documents, primarily the RIC or foreign permanent residence ID, which are themselves closely tied to citizenship or approved permanent residency status.[64] As a result, stateless individuals who are unable to secure birth registration or hukou registration are excluded from both physical and digital identity systems.[65] This is despite Article 7 of the Nationality Law of the People’s Republic of China formally providing pathways for foreign or stateless persons to acquire nationality and become eligible for an RIC, though the implementation of these provisions are uncertain.

As stateless persons cannot apply for a digital ID, they are also excluded from a wide range of State-sponsored and State-enabled services that rely on digital identity verification.[66] These include access to government e-services, healthcare and medical insurance systems, education platforms, employment registration, banking and financial services, transportation booking systems, and major commercial and social media platforms. There are no alternative avenues available for stateless individuals to access digital public services, leaving them dependent on informal arrangements or entirely excluded from digital systems.

The current legal and policy framework does not have specific safeguards for stateless persons or other vulnerable groups within the digital ID system.[67] There are no reported provisions for mobile registration units, legal aid, or exemptions from documentation requirements. There are however strong concerns raised by human rights groups and academics on the potential for intensified state surveillance, censorship, and control targeting human rights defenders and other dissenters.[68] Without any reforms to ensure all residents (regardless of citizenship status) can access essential services, ensure universal and safe birth registration, and remove restrictions on the freedom of expression in online spaces, China’s digital ID system remains designed around citizenship and is seen as a tool for mass state surveillance and censorship of digital spaces. 

References
1.^

 ‘China: Vital Documents and Identification’ (I Am Here: obtaining your identification and vital documents) <https://iamhere.bakermckenzie.com/en/pages/china> accessed 6 January 2026.

2.^

ibid

3.^

 ‘DFAT Country Information Report People’s Republic Of China’.

4.^

ibid

5.^

ibid

6.^

 United Nations High Commissioner for Refugees, ‘Refworld | China: Procedures for Issuing Second-Generation Resident Identity Cards (RICs), Including Whether the Procedures Vary in Different Parts of China; Application Processing Times and Whether Validity Periods Are Assigned When the Application Is Made or When the Card Is Issued’ (Refworld) <https://webarchive.archive.unhcr.org/20230601205040oe_/https://www.refworld.org/docid/4e2fbf462.html> accessed 6 January 2026; ‘China: Vital Documents and Identification’ (n 1).

7.^

 ‘China: Vital Documents and Identification’ (n 1).

8.^

 Nationality Law of the People’s Republic of China 1980.

9.^

 ‘China: Vital Documents and Identification’ (n 1).

10.^

ibid

11.^

 Law of the People’s Republic of China on Resident Identity Cards (2011 Amendment) 2011.

12.^

 ‘Should a Foreign and a Stateless Person Who Resides in the Territory of the People’s Republic of China and Was Approved to Acquire or Restore the Nationality of the People’s Republic of China Apply for a Resident Identity Card?’ <http://en.moj.gov.cn/2019-06/20/c_383617.htm> accessed 6 January 2026.

13.^

 ‘Apply for Chinese Nationality_National Immigration Administration’ <https://en.nia.gov.cn/n147428/n147498/n147765/n147865/c158777/content.html> accessed 19 January 2026.

14.^

 lawyerschina.net, ‘Obtain Birth Certificate in China’ (Lawyers China, 21 December 2022) <https://lawyerschina.net/obtain-birth-certificate-in-china/> accessed 6 January 2026.

15.^

 ‘China: Vital Documents and Identification’ (n 1).

16.^

 ‘China’s Hidden Children: Denied Documents and at Risk of Statelessness’ (European Network on Statelessness, 19 January 2017) <https://www.statelessness.eu/updates/blog/chinas-hidden-children-denied-documents-and-risk-statelessness> accessed 19 January 2026.

17.^

 Codings, ‘HUKOU SYSTEM IN CHINA’ <https://orcasia.org/hukou-system-in-china> accessed 6 January 2026.

18.^

 Guofu Liu and Qian Zhu, ‘The Challenges Faced by Unregistered Individuals in China’s Household Registration System: An Approach Focused on Rights’ [2025] Journal of Family History 03631990251380132; ‘Chinese Star School Pupil Barred from Taking University Entrance Exam’ (South China Morning Post, 16 September 2015) <https://www.scmp.com/news/china/policies-politics/article/1858673/chinese-star-school-pupil-barred-taking-university> accessed 6 January 2026.

19.^

 Fintech News Hong Kong, ‘China Launches Cyber ID System Despite Privacy Backlash’ (Fintech Hong Kong, 17 July 2025) <https://fintechnews.hk/34740/fintechchina/china-cyber-id-system-privacy-concerns/> accessed 7 January 2026; TechNode Feed, ‘China Rolls out National Online ID Card Platform for Secure Digital Identity Verification · TechNode’ (TechNode, 16 July 2025) <https://technode.com/2025/07/16/china-rolls-out-national-online-id-card-platform-for-secure-digital-identity-verification/> accessed 7 January 2026.

20.^

 ‘“Internet ID Card” Has Been Officially Launched, You Have Received It? - Social and Rule of Law - People’s Network’ <http://society.people.com.cn/n1/2025/0716/c1008-40523119.html> accessed 7 January 2026.

21.^

ibid

22.^

 ‘Measures for the Administration of National Public Services for Online Identity Authentication’ <https://www.lawinfochina.com/display.aspx?id=44793&lib=law&SearchKeyword=&SearchCKeyword=> accessed 7 January 2026.

23.^

 China Law Translate, ‘Measures on the Management of the National Online Identity Authentication Public Service’ (China Law Translate, 23 May 2025) <https://www.chinalawtranslate.com/online-id-2/> accessed 7 January 2026.

24.^

 ‘China’s New Web ID Tightens Government’s Grip on Online Activity | Merics’ (2 December 2025) <https://merics.org/en/comment/chinas-new-web-id-tightens-governments-grip-online-activity> accessed 7 January 2026.

25.^

ibid

26.^

 John Liu, ‘China Tightens Internet Controls with New Centralized Form of Virtual ID | CNN Business’ (CNN, 20 June 2025) <https://www.cnn.com/2025/06/20/tech/china-censorship-internet-id-hnk-intl> accessed 7 January 2026.

27.^

 ‘China: New Internet ID System a Threat to Online Expression’ (ARTICLE 19, 25 June 2025) <https://www.article19.org/resources/china-new-internet-id-system-a-threat-to-online-expression/> accessed 7 January 2026.

28.^

ibid

29.^

ibid

30.^

 ‘“Internet ID Card” Has Been Officially Launched, You Have Received It? - Social and Rule of Law - People’s Network’ (n 20).

31.^

 Codings, ‘HUKOU SYSTEM IN CHINA’ <https://orcasia.org/hukou-system-in-china> accessed 6 January 2026.

32.^

 Joel R McConvey, ‘China Starts National Digital ID Trial Barely a Week after Releasing Draft Plan | Biometric Update’ (6 August 2024) <https://www.biometricupdate.com/202408/china-starts-national-digital-id-trial-barely-a-week-after-releasing-draft-plan> accessed 7 January 2026.

33.^

 ‘Announcement of the State Internet Information Office of the Ministry of Public Security on the Public Security Measures for the Administration of Public Service for Network Identity Verification (Draft for Comment)’ (17 July 2025) <https://web.archive.org/web/20250717032155/https:/www.cac.gov.cn/2024-07/26/c_1723675813897966.htm> accessed 7 January 2026.

34.^

 McConvey (n 32).

35.^

 ‘China’s New Digital ID System Trialed Across Over 80 Apps’ <https://www.caixinglobal.com/2024-08-03/chinas-new-digital-id-system-trialed-across-over-80-apps-102223181.html> accessed 7 January 2026.

36.^

 ‘China: CAC Publishes Measures for Administration of National Network Identity Authentication Public Services | News’ (DataGuidance) <https://www.dataguidance.com/news/china-cac-publishes-measures-administration-national> accessed 7 January 2026.

37.^

 ‘China: CAC Publishes Measures for Administration of National Network Identity Authentication Public Services | News’ (DataGuidance) <https://www.dataguidance.com/news/china-cac-publishes-measures-administration-national> accessed 19 January 2026.

38.^

 ‘Measures for the Administration of National Public Services for Online Identity Authentication’ (n 22).

39.^

ibid

40.^

 QingYun Wan, ‘New Measure to Ensure Online Safety’ <https://www.chinadaily.com.cn/a/202505/24/WS68310438a310a04af22c144a.html> accessed 19 January 2026.

41.^

 Translate (n 23).

42.^

 ‘Personal information’ is defined in the CSL as all kinds of information, recorded electronically or through other means, that taken alone or together with other information, is sufficient to identify a natural person’s identity, including but not limited to natural persons’ full names, birth dates, national identification numbers, personal biometric information, addresses, telephone numbers, and so forth.

43.^

 China Briefing, ‘The PRC Personal Information Protection Law (Final): A Full Translation’ (China Briefing News, 24 August 2021) <https://www.china-briefing.com/news/the-prc-personal-information-protection-law-final-a-full-translation/> accessed 8 January 2026.

44.^

 ‘Data Protection Laws in China - Data Protection Laws of the World’ <https://www.dlapiperdataprotection.com/index.html?c=CN> accessed 8 January 2026.

45.^

 ‘Translation: Cybersecurity Law of the People’s Republic of China (Effective June 1, 2017)’ (DigiChina) <https://digichina.stanford.edu/work/translation-cybersecurity-law-of-the-peoples-republic-of-china-effective-june-1-2017/> accessed 8 January 2026.

46.^

 China Briefing, ‘The PRC Personal Information Protection Law (Final): A Full Translation’ (China Briefing News, 24 August 2021) <https://www.china-briefing.com/news/the-prc-personal-information-protection-law-final-a-full-translation/> accessed 8 January 2026.

47.^

 ‘China’s Handling of Biometric Data: Trends and Implications for Europe | Merics’ (17 December 2025) <https://merics.org/en/events/chinas-handling-biometric-data-trends-and-implications-europe> accessed 8 January 2026.

48.^

 Briefing (n 46).

49.^

 ‘Translation: Cybersecurity Law of the People’s Republic of China (Effective June 1, 2017)’ (n 45).

50.^

 ‘China Introduces National Cyber ID Amid Privacy Concerns | Chinese Human Rights Defenders’ <https://www.nchrd.org/2025/07/china-introduces-national-cyber-id-amid-privacy-concerns/> accessed 8 January 2026.

51.^

 John Liu, ‘China Tightens Internet Controls with New Centralized Form of Virtual ID | CNN Business’ (CNN, 20 June 2025) <https://www.cnn.com/2025/06/20/tech/china-censorship-internet-id-hnk-intl> accessed 19 January 2026.

52.^

 ‘China’s New Web ID Tightens Government’s Grip on Online Activity | Merics’ (2 December 2025) <https://merics.org/en/comment/chinas-new-web-id-tightens-governments-grip-online-activity> accessed 8 January 2026.

53.^

 Liu (n 26).

54.^

 ‘China’s New Web ID Tightens Government’s Grip on Online Activity | Merics’ (n 52); Liu (n 26).

55.^

 ‘China: Draft Internet ID Measure Threatens to Tighten Online Censorship’ (ARTICLE 19, 5 February 2025) <https://www.article19.org/resources/china-draft-internet-id-measure-tightening-online-censorship/> accessed 8 January 2026.

56.^

 Masha Borak, ‘China’s Online ID Plans Could Inspire Authoritarian Regimes Say Human Rights Groups | Biometric Update’ (6 February 2025) <https://www.biometricupdate.com/202502/chinas-online-id-plans-could-inspire-authoritarian-regimes-say-human-rights-groups> accessed 8 January 2026.

57.^

 ‘Ratification Status for China’ <https://tbinternet.ohchr.org/_layouts/15/TreatyBodyExternal/treaty.aspx> accessed 9 January 2026.

58.^

 ‘Concluding Observations on the Ninth Periodic Report of China’ (Committee on the Elimination of Discrimination against Women 2023) <https://digitallibrary.un.org/record/4013939/files/CEDAW_C_CHN_CO_9-EN.pdf>; ‘Concluding Observations on the Combined Fourteenth to Seventeenth Periodic Reports of China (Including Hong Kong, China and Macao, China)*’ (Committee on the Elimination of Racial Discrimination 2018) <https://documents.un.org/doc/undoc/gen/g18/279/46/pdf/g1827946.pdf> accessed 9 January 2026.

59.^

 ‘General Comment No. 25 (2021) on Children’s Rights in Relation to the Digital Environment’ 25 <https://www.unicef.org/bulgaria/en/media/10596/file>.

60.^

 ‘Concluding Observations on the Combined Third and Fourth Periodic Reports of China (Including Hong Kong and Macau Special Administrative Regions), Adopted by the Committee at Its Sixty-Fourth Session (16 September – 4 October 2013)’ (Refworld) <https://www.refworld.org/policy/polrec/crc/2013/en/96093> accessed 9 January 2026.

61.^

 ‘General Comment No. 25 (2021) on Children’s Rights in Relation to the Digital Environment’ <https://www.unicef.org/bulgaria/en/media/10596/file>.

62.^

 ‘Report on the Third Ministerial Conference on Civil Registration and Vital Statistics in Asia and the Pacific’ (United Nations Economic and Social Commission for Asia and the Pacific 2025) <https://www.unescap.org/sites/default/d8files/event-documents/2500210E_ESCAP_MCCRVS_2025_6_Report_3rd_Ministerial_Conference_on_CRVS.pdf> accessed 17 December 2025.

63.^

ibid

64.^

 Translate (n 23).

65.^

 ‘Concluding Observations on the Combined Third and Fourth Periodic Reports of China (Including Hong Kong and Macau Special Administrative Regions), Adopted by the Committee at Its Sixty-Fourth Session (16 September – 4 October 2013)’ (n 60); ‘Concluding Observations on the Combined Fourteenth to Seventeenth Periodic Reports of China (Including Hong Kong, China and Macao, China)*’ (n 58).

66.^

 ‘Concluding Observations on the Ninth Periodic Report of China’ (n 58).

67.^

 Translate (n 23).

68.^

 Liu (n 26); ‘China: Draft Internet ID Measure Threatens to Tighten Online Censorship’ (n 55).

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