Cross-border data freedom in China now arrives by delisting, not by deregulation.
Facilitation is delivered only as enumerated carve-outs — citywide negative lists and streamlined procedures for delisted transfers — while assessment duties, numeric thresholds, and enforcement campaigns keep every unassessed or unlisted export fully liable.
The same conclusion keeps arriving from across the workspace's research — 1 topics independently instantiate this theme. Filter the evidence by where it came from:
The enforcement campaign fines flows outside published channels in the same month that guidelines promise 'more efficient, convenient and secure' cross-border movement.
Shanghai's expansion widens the delisted corridor citywide while numeric 'important data' thresholds and continuing PIPIA, logging, and reporting duties fence everything else.