Further amendments to the proposed China e-commerce law have been announced which will require e-commerce platform and marketplace providers to provide users with practical mechanisms to access their users’ information, make corrections or deletions of their information, and close their accounts. E-commerce operators will also be prevented from circumventing these requirements though onerous contractual conditions which might otherwise be used to make it difficult for users to request access, correct and deletion of information or to close their accounts. In many cases, e-commerce operators will find themselves needing to build this additional functionality into their front end user interfaces and back end systems.

In line with the objectives of the recent Cybersecurity Law, e-commerce operators also face obligations to protect network security and to maintain incident response plans, which will need to be implemented immediately following a Cyber incident. Many business are now in the process of developing customised cyber response plans for their China operations.