China's real-name rules have long pushed every app, game and service to collect and store copies of national ID numbers, and each of those stores is a breach waiting to happen. The Measures for the National Network Identity Authentication Public Service (国家网络身份认证公共服务管理办法), issued as Ministry of Public Security Order No. 173 together with the Cyberspace Administration of China (CAC) and four other departments, took effect on 15 July 2025. They create a state-run service that issues each citizen a network number (网号, often called a "cyberspace ID") and a network certificate (网证), so platforms can verify real identity without receiving the plaintext ID number. This guide explains the 16 articles, what changes for platforms that connect, the data handling and security duties, how the service fits with PIPL, the Cybersecurity Law and real-name rules, and what multinational product, identity and privacy teams should decide. It is for identity architects, privacy officers and compliance leads running consumer services in mainland China.
Source note: article content is from the full Chinese text of the Measures (MPS Order No. 173) as published on 12371.cn, and dates from Xinhua and the CAC draft notice; English renderings are ours. Confirm against the official text before relying on it.
Key takeaways
- Voluntary for users and platforms, on paper. Article 4 lets citizens apply voluntarily, Article 7 encourages but does not require internet platforms to connect, and Article 6 tells government and key industries to keep existing lawful verification methods.
- Two artefacts, one identity. The 网号 is a unique alphanumeric identifier with no plaintext identity data; the 网证 is a credential that carries the 网号 and non-plaintext identity information. Both are issued by the national platform from a statutory ID document.
- Connected platforms must stop asking for ID numbers. Once a user verifies with a 网号 or 网证, a platform may not demand plaintext identity data unless a law requires it or the user agrees, and must give equal service to users who do not use the service.
- Minimum data by design. Article 8 says a platform that only needs to verify identity receives only the verification result; retained identity data needs user authorisation or separate consent and the minimum necessary.
- Penalties come from the core data laws. Article 14 applies the Cybersecurity Law, Data Security Law and Personal Information Protection Law to breaches of Articles 7, 8, 9, 11 and 12.
What the Measures are and their status
The Measures were adopted at a Ministry of Public Security ministerial meeting on 27 February 2025, dated 19 May 2025, published on 23 May 2025 and took effect on 15 July 2025 (Article 16). The six issuing departments are the Ministry of Public Security (MPS), the Cyberspace Administration of China, the Ministry of Civil Affairs, the Ministry of Culture and Tourism, the National Health Commission and the National Radio and Television Administration. A draft for comment was published by the MPS and CAC on 26 July 2024 with comments due by 25 August 2024; the final text keeps the 16-article structure of the draft.
Article 1 names the legal basis: the Cybersecurity Law, Data Security Law, Personal Information Protection Law, Anti-Telecom and Online Fraud Law and the Law on the Protection of Minors. The stated purpose is to implement a trusted online identity strategy, protect citizens' identity information and support the digital economy. Under Article 3, the MPS and CAC lead supervision, with the other departments acting within their remits. The measures are departmental rules, which sit below national laws and State Council regulations in China's legal hierarchy.
| Date | Event |
|---|---|
| 26 July 2024 | MPS and CAC publish the draft for public comment |
| 25 August 2024 | Comment period closes |
| 27 February 2025 | Adopted at MPS ministerial meeting |
| 19 May 2025 | Measures signed as MPS Order No. 173 |
| 23 May 2025 | Published |
| 15 July 2025 | In force (Article 16); national platform and app live |
How the service works
- Network number (网号): a unique, permanent code of letters and digits linked one-to-one to a person, containing no plaintext name or ID number (Article 2).
- Network certificate (网证): a credential carrying the 网号 and non-plaintext identity information. State media describe it as a dynamic, encrypted credential that can be shown as a QR code, not a new ID card.
- Enrolment: an adult downloads the 国家网络身份认证 (National Network Identity Authentication) app on an NFC-capable phone, chooses the document type, reads the chip of a valid resident ID card over NFC, completes face recognition, links a phone number and sets a credential password. Expired or lost ID cards must be renewed first.
- Verification: the user authorises a check at a connected platform; the national platform returns a result or, where law requires retained identity data, the minimum necessary data with consent (Article 8). Identity data stays on the MPS national platform.
- Eligible documents (Article 15): resident ID cards, passports for citizens living abroad, travel permits for Hong Kong, Macau and Taiwan residents, residence permits for those residents, and foreign permanent residence ID cards.
- Minors (Articles 4 and 5): under 14 needs guardian consent and a guardian applies on the child's behalf; 14 to 17 apply under guardian supervision. Article 10 lets the service give platforms age indicators so they can meet minor protection duties.
Before the Measures took effect, state media (Xinhua, May 2025) reported millions of app downloads and authentication requests during the pilot, across government services, education and examinations, culture and tourism, healthcare, postal delivery and transport. We could not verify those figures independently, so they are not repeated here.
Article-by-article reference
| Article | Subject | Who it binds |
|---|---|---|
| 1 | Purpose and legal basis | All |
| 2 | Definitions of the public service, 网号 and 网证 | All |
| 3 | Supervising departments (MPS and CAC lead) | Regulators |
| 4 | Voluntary application, minors | Individuals |
| 5 | Use where law requires real-name registration or verification | Individuals, platforms |
| 6 | Voluntary adoption by public sector and key industries, existing methods kept | Public bodies, key industries |
| 7 | Voluntary platform connection; no plaintext ID demands after verification; equal service | Internet platforms |
| 8 | Result-only verification; minimum necessary data with consent where retention is legally required | Internet platforms, service operator |
| 9 | Service operator: necessity, notice, consent, separate consent for sensitive data, purpose limitation, deletion | Public service platform |
| 10 | Age indicators for minors and support for elderly users | Public service platform |
| 11 | Notice content and limited exceptions | Public service platform |
| 12 | Security management, domestic storage, cross-border security assessment, incident response and reporting | Public service platform |
| 13 | Compliance with national cryptography management requirements | Public service platform |
| 14 | Liability under CSL, DSL and PIPL; criminal liability; official misconduct | All |
| 15 | Statutory identity documents | All |
| 16 | Effective 15 July 2025 | All |
Platform duties when you connect
Connection is voluntary, but once a platform connects the duties are not. The practical design questions are what data you still need and what you can delete.
- Stop collecting plaintext identity by default: after a successful 网号 or 网证 verification you may not ask for the ID number unless a law or regulation requires it or the user agrees (Article 7). Design the user journey so that consent to share more is a genuine choice, not a gate.
- Keep the old route open: users who do not use the service must get the same service (Article 7), so the existing real-name flow must keep working.
- Prefer result-only checks: if your obligation is to verify real identity rather than retain it, request only the result (Article 8). Sectors that must keep identity records (for example where telecoms, finance or hotel rules require them) receive the minimum necessary data after authorisation or separate consent.
- Treat what you receive as sensitive personal information: identity data and any face data remain sensitive under PIPL Article 28, with separate consent and impact assessment duties. See the China PIPL Guide.
- Use age indicators: the age signal from Article 10 can support minor mode and gaming time limits without collecting a birth date.
- Record the integration: document the data flow, legal basis and retention for your PIPL records and any compliance audit. See the China Personal Information Protection Compliance Audits guide.
How it fits with China's other identity and data rules
| Rule | Relationship to the Measures |
|---|---|
| Cybersecurity Law real-name requirements | Network operators must verify real identity for many services; Article 5 lets users meet that requirement with a 网号 or 网证. See the China Cybersecurity Law Guide |
| Personal Information Protection Law | Governs consent, sensitive data and minimisation for both the platform and the service; penalties apply through Article 14 |
| Data Security Law and network data rules | Apply to important data handled by the service. See the China Data Security Law and Network Data Security Regulations Guide |
| Cross-border rules | Article 12 requires domestic storage and a security assessment for any overseas transfer. See the China Cross-Border Data Transfers guide |
| Cryptography Law | Article 13 requires national cryptography management compliance. See the China Cryptography Law guide |
| Anti-Telecom and Online Fraud Law | Named in Article 1 as a legal basis; real-name verification is a core anti-fraud control |
Comparison with other national digital identity models
| Feature | China 网号 and 网证 | EU Digital Identity Wallet (eIDAS 2.0) | India Aadhaar authentication |
|---|---|---|---|
| Who holds identity data | Central MPS platform | Wallet on the user's device, issued attestations | Central UIDAI repository |
| What the relying party receives | Verification result, or minimum data with consent | Selected attributes the user discloses | Yes or no result or e-KYC data |
| User participation | Voluntary | Voluntary for users | Widely required in practice for many services |
| Relying party participation | Voluntary connection | Some sectors must accept the wallet | Authorised entities only |
The central model reduces scattered ID number copies, but it also concentrates identity data and the record of where people authenticate in one state platform. Multinationals should weigh that concentration in their own risk assessment as a policy question, not only a technical one. See the eIDAS 2.0 and the European Digital Identity Framework Guide and the India Aadhaar and Digital Public Infrastructure guide for those models.
Deciding whether to connect
| Factor | Points towards connecting | Points towards waiting |
|---|---|---|
| Breach exposure | You store large volumes of ID numbers and want to delete them | You must retain identity records anyway under sector rules |
| User base | Domestic citizens with NFC phones and ID cards | Many foreign users without eligible documents |
| Sector signals | Regulators in your sector are piloting or encouraging use | Your regulator has not addressed it |
| Engineering | Your identity layer already abstracts verification providers | Real-name checks are hard coded in many services |
| Group policy | Group privacy policy accepts state platform verification | Group policy has unresolved concerns about centralised identity data |
Implementing an integration
- Map every real-name touchpoint: list where you collect, verify, store and display ID numbers and face data, and the law that requires each one.
- Classify each touchpoint: verify-only, or verify-and-retain. Verify-only flows are the candidates for result-only checks.
- Design the dual path: add the 网号 or 网证 option alongside the existing flow, with equal service for both, and consent screens for any extra data.
- Pilot one product: start with a low-risk service, run both paths in parallel, and compare verification success rate and abandonment.
- Delete legacy data: for verify-only flows, delete stored ID numbers that are no longer needed, with a documented retention decision.
- Update PIPL documentation: privacy notices, records of processing and personal information protection impact assessments.
- Plan rollback: keep the original verification path live so that an outage of the national platform does not block users.
Where identity fits for machine identities
The integration itself creates non-human identities: the platform's credentials to call the national service, API keys or certificates, and the backend services that receive results. Store those credentials in a secrets manager, rotate them, restrict which services can call the verification API, and log every call with a request ID, so that an attacker who compromises a backend cannot query identities at scale. See the Secrets Management Guide.
Measuring the change
- Plaintext ID holdings: number of stored ID numbers, trending down after verify-only flows move to result-only checks.
- Adoption share: percentage of real-name verifications completed through the national service.
- Verification success and abandonment: compared across the two paths.
- Consent rate for extra data: how often users agree to share more, which shows whether the choice is genuine.
- Availability fallbacks: number of times the fallback path was used because the national platform was unavailable.
Common failure patterns
- Connecting but still collecting: keeping the old form that asks for the ID number after a 网号 check, which Article 7 prohibits without a legal requirement or consent.
- Degrading the non-user path: making the traditional flow slower or limited to push adoption, which breaches the equal service duty.
- Keeping legacy stores: adopting the service while leaving years of copied ID numbers in databases and logs.
- Treating it as mandatory: blocking users who do not enrol, or assuming foreign users have eligible documents.
- Weak API credentials: long-lived keys for the verification integration shared across services, turning one compromise into bulk identity queries.
Framework mapping
| Measures requirement | NIST SP 800-53 Rev 5 | NIST CSF 2.0 |
|---|---|---|
| Identity proofing against statutory documents | IA-12 Identity Proofing | PR.AA-02 |
| Minimum data and purpose limitation (Articles 8 and 9) | IA-12, data minimisation in the PT family | GV.OC-03 |
| Security and incident duties (Article 12) | IR-4 Incident Handling | RS.MA-01 |
| Data protection in storage and transit | SC-28, SC-8 | PR.DS-01, PR.DS-02 |
| Integration credentials | AC-6 Least Privilege | PR.AA-01 |
Practitioner checklist
- Inventory every place your China services collect, verify or store ID numbers and face data.
- Record the legal requirement behind each touchpoint and whether it requires retention.
- Decide, with legal and group privacy, whether to connect to the national service.
- If you connect, offer it alongside the existing flow and keep service equal for both paths.
- Use result-only verification wherever retention is not legally required, and delete legacy ID copies.
- Update privacy notices, processing records and impact assessments under PIPL.
- Protect integration credentials in a secrets manager with rotation and call logging.
- Keep a fallback path for national platform outages and monitor its use.
Standards and references
- Ministry of Public Security and CAC: Measures for the National Network Identity Authentication Public Service (full text)
- Xinhua: Publication of MPS Order No. 173 on the national network identity authentication public service
- Cyberspace Administration of China: Draft Measures for public comment
- Xinhua: National network identity authentication, how to apply
- Xinhua and People's Daily: National network identity authentication now in effect
- NIST: SP 800-53 Rev. 5 Security and Privacy Controls
Related NHI Mgmt Group resources: China PIPL Guide · China Cybersecurity Law Guide · China Cross-Border Data Transfers · Digital Identity Wallets Guide. This guide summarises China's Measures for the National Network Identity Authentication Public Service and is not legal advice.