AI law comparison · Data verified 2026-08-22
China PIPL vs GDPR Article 22
China PIPL and GDPR Article 22 are two of the 169 AI and data regulations Aegis Firma tracks. They have different scopes, effective dates, and penalties — and many businesses fall under both. Here is the side-by-side, drawn directly from the regulatory registry.
Find which laws apply to my businessSide by side
Summary of publicly available regulatory text. Verify against current official sources before relying on this for compliance decisions. Not legal advice.
The key difference
GDPR Article 22 takes effect first, so it is usually the more urgent of the two. China PIPL tracks 5 compliance requirements and GDPR Article 22 tracks 5. They are not interchangeable — meeting one does not discharge the other. The practical question is not which law is “stricter,” but which of them — or both — actually applies to your business.
China Personal Information Protection Law (PIPL)
China's Personal Information Protection Law (PIPL, effective November 1, 2021) is China's primary personal data protection law, comparable in scope to GDPR but with distinct Chinese characteristics. PIPL directly affects AI systems by: requiring consent for AI profiling, mandating transparent disclosure of automated decision-making, prohibiting unreasonable differentiated treatment (pricing discrimination), and impos…
Full China PIPL requirementsEU GDPR Article 22 — Automated Decision-Making & AI Profiling
GDPR Article 22 (in force since May 25, 2018) gives EU and EEA residents the right not to be subject to decisions based solely on automated processing — including AI profiling — that produces legal or similarly significant effects (credit scores, hiring, insurance pricing, content moderation). Organizations must inform individuals of automated processing, provide meaningful explanations of logic, implement human revi…
Full GDPR Article 22 requirementsCommon questions
Could both China PIPL and GDPR Article 22 apply to my business?
Yes. China PIPL and GDPR Article 22 are separate regulations with separate scopes — a business can fall under both at once. China PIPL covers Extraterritorial reach: applies to processing of personal information of persons within China regardless of where the processing entity is located. GDPR Article 22 covers GDPR Art. If your operations meet both scopes, you must comply with both. Aegis Firma's free scan checks all 169 tracked regulations against your business profile so you do not have to read each law to find out.
Which has the higher maximum penalty — China PIPL or GDPR Article 22?
China PIPL: ¥50,000,000 or 5% of annual revenue (whichever is higher); service suspension; individual liability for responsible persons up to ¥1,000,000 GDPR Article 22: €20,000,000 or 4% of global annual turnover — whichever is higher (GDPR Art. 83(5)) Penalty structures differ by regulator and violation type — read each law's full page for the cure periods and per-violation detail.
When does each law take effect?
China PIPL — effective 2021-11-01. GDPR Article 22 — effective 2018-05-25. Dates last verified against official sources on 2026-08-22 and 2026-08-22 respectively.
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