Decoding China’s Data Element Policies: Implications and Strategies

1. National Commitment to Data Elements and Policy Landscape

Since the 19th Party Congress in 2019 first classified data as a production factor, China has issued a series of top‑level policies to build a data‑element market. Key milestones include the 2022 joint issuance of the "Opinions on Building a Data Basic System" outlining 20 measures across data ownership, circulation, revenue sharing, and security governance, and the establishment of the National Data Bureau in October 2023, which later released the three‑year action plan (2024‑2026) for data elements. Recent documents such as the 2024 "Opinions on Accelerating Public Data Resource Development" and the "National Data Infrastructure Construction Guidelines" further refine the policy framework, indicating a rapidly maturing national data‑element system (see Table 1).

2. Provincial and Municipal Initiatives

Local governments have set ambitious data‑element development targets. For example, Shanghai aims for a 15% annual compound growth and a 5 trillion‑yuan industry scale by 2025, fostering 1,000 data‑commerce enterprises. Numerous provinces have established data‑group companies (over 110 nationwide) and data exchanges, each tailoring functions to regional economic priorities (see Tables 2‑3).

3. Data Infrastructure as a Foundation

Recent policies repeatedly stress the construction of a trustworthy data infrastructure that supports data‑driven productivity. The 2024 "National Data Infrastructure Construction Guidelines" defines a four‑layer architecture (network, computing, data‑flow, and security facilities) and sets targets: by 2026, pilot technical routes for key industries; by 2028, nationwide coverage of large‑ and medium‑size cities; by 2029, a coordinated, scalable, and trustworthy data‑circulation system.

The concept of a "trusted data space" is highlighted as a new model for secure data sharing. The 2024‑2028 Action Plan outlines five categories of trusted data spaces (enterprise, industry, city, personal, cross‑border) and describes their inter‑relationships (see Figure 4).

4. Public Data as a Key Growth Engine

Public data generated by government agencies and state‑owned enterprises is identified as a high‑value, circulable resource. A "1+3" policy framework (one overall plan plus three supporting measures) released in October 2024 aims to remove barriers to public data development. The framework defines three authorization models—overall, sector‑specific, and scenario‑based—and is backed by detailed implementation guidelines (see Tables 5‑6).

More than 30 provinces have built public‑data authorization platforms, moving toward standardized, regulated infrastructures (see Table 7).

5. Strategic Reflections for Financial Institutions

Financial firms, as major data consumers, must align with the evolving policy environment. The article proposes two complementary approaches:

Deepen data‑element value extraction: leverage internal data assets, create external data‑link mechanisms, establish internal data‑marketplaces, and implement robust data‑valuation and governance frameworks.

Integrate into the data‑element ecosystem: pilot trusted data spaces, contribute to standard‑setting, partner with data‑industry players, and provide financial services that support data‑driven enterprises.

These recommendations aim to help banks capture the multiplier effect of data, ensure secure and efficient data flows, and support the broader digital economy.