We explain the latest regulations on the use of facial recognition in China. On March 30, 2025, the Cyberspace Administration of China (CAC) issued a notice clarifying filing requirements for companies that use facial recognition technology to process and store facial data of a certain number of individuals. Filing requirements for companies storing facial recognition informationUnder Article 15 of the Security Management Measures, companies that store facial recognition data of over 100,000 individuals are required to register with the provincial-level cyberspace administration within 30 working days from the date this threshold is reached. Conducting a PIPIAUnder China’s Personal Information Protection Law (PIPL), companies that engage in certain personal information processing activities are required to carry out a PIPIA. The Filing Instructions have provided a specific template for conducting a PIPIA for facial recognition information processing.