On June 30, 2026, China’s National Energy Administration (NEA) officially issued the Guidelines for Classification and Grading of Energy Industry Data (2026 Version) (hereinafter referred to as “the Guidelines”), which took effect on July 1, 2026. The new rules establish a unified framework for classifying and securing non-confidential data across the country’s energy sector, marking a significant step in implementing the Data Security Law and strengthening the governance of energy industry data.

The Guidelines, consisting of 4 chapters and 15 articles, are designed to help data processors accurately identify and protect “important data” and “core data” within the energy industry. Specifically, Chapter I (General Provisions) covers the purpose, legal basis, scope, and the main principles behind the Guidelines; Chapter II lays out the rules for classifying and grading energy data, and also addresses how derivative data and anonymized data should be handled; Chapter III provides specific criteria for identifying important and core data; Chapter IV (Supplementary Provisions) defines key terms, explains how the Guidelines can be revised, who has the authority to interpret them, and when they take effect.

They work in tandem with the Measures for Data Security Management in the Energy Industry (Trial), which were also issued by the NEA and took effect on the same day, forming the foundational regulatory framework for energy data security. Additional supporting regulations are expected to follow.

Under the Guidelines, energy data are classified by two primary dimensions: energy variety (coal, petroleum, natural gas, nuclear, hydropower, wind, solar, biomass, geothermal, marine, electricity, and hydrogen) and energy activity (planning, design, construction, production, storage and transportation, consumption, and scientific research). Data processors may further establish tertiary and quaternary classifications based on specific data characteristics.

Energy data are graded into three levels, namely general, important, and core, based on data importance, precision, scale, and security risks, with the distinction between important and core data determined by the degree of harm to national security in the event of leakage or tampering. Derivative data (e.g., from statistical analysis, correlation, mining, or aggregation) retain the original grade if the original data can be restored. Properly anonymized data that cannot be restored may be downgraded: core to important or general, and important to general.

The Guidelines lay out specific, measurable criteria for identifying important energy data.

For geolocation data, the threshold is set at precision of 100 meters or better, and this applies to key energy infrastructure such as coal mines with annual output of 10 million tons or more, thermal power plants with single-unit capacity of 1 GW or more (or total installed capacity of 3 GW or more), hydropower stations (excluding pumped-storage) with installed capacity of 1.2 GW or more or reservoir capacity of 1 billion cubic meters or more, nuclear power plants, and substations or converter stations above 750 kV. Any documents containing such coordinate data, whether for planning, design, construction, operations and maintenance, or research, are also covered under this rule.

The same goes for real-time operational command data, but only for the facility categories listed above, plus the national pipeline network control center. On the electricity consumption side, the criteria cover data for special-grade and military-grade important power users, as well as any dataset that includes 10 million or more individual power users.

Data qualifies as core data if it meets more stringent thresholds: one or more consecutive years of raw consumption data for special-grade important power users, or raw consumption data covering 100 million or more power users.

The identification rules for important and core data are subject to ongoing review and will be revised as needed based on national security considerations. Supplementary provisions will be issued when other energy data are newly designated as important or core.

For foreign stakeholders, the Guidelines represent a key compliance consideration, particularly in areas such as data export, cross-entity transfer of core data, and annual risk assessments. Relevant parties are advised to review their data processing activities against the Guidelines and stay informed of future supporting regulations.