Unveiling China’s Legal Leverage

In a move that sparks intense scrutiny and debate, China has introduced a law requiring any technology company operating within its borders to disclose information about security vulnerabilities in their products. Rooted in a two-day reporting window, the law has ramifications that extend to multinational corporations and state-sponsored hacking activities.

A New Twist to an Old Game

Traditionally, state-sponsored hacking operations have relied on a cache of undisclosed vulnerabilities, often purchased secretly. In a break from this approach, China’s law mandates that technology companies disclose these vulnerabilities to the Ministry of Industry and Information Technology within 48 hours. The law adds another layer of complexity for both local and foreign companies, as non-compliance could result in severe repercussions, including the loss of business licenses.

A Complex Web of Information Sharing

Information reported is not kept within the confines of a single agency. Several governmental bodies, such as China’s National Computer Network Emergency Response Technical Teams/Coordination Center (CNCERT/CC), are privy to these details. Of concern is that this information also reaches state-sponsored hacking organizations, potentially fueling offensive cyber capabilities.

The Devil is in the Details

While it might appear that the law demands generic vulnerability information, the reporting portal includes fields asking for highly specific details like where in the code to “trigger” the vulnerability. This level of granularity can potentially aid in the development of hacking tools designed to exploit these vulnerabilities.

A Question of Compliance

Several foreign firms operating in China are suspected of complying with this law, although responses from these companies have been ambiguous at best. Some companies deny sharing unpatched vulnerabilities, while others claim to share only innocuous information—equally disseminated to other governments and their customers.

Unforeseen Geopolitical Consequences

The implications of this law stretch beyond China’s borders. With cyber-tensions between China and the United States escalating, the prospect of a legal pathway for Chinese authorities to gain access to a reservoir of hackable flaws raises concerns about the geopolitical landscape.

A Gap in Corporate Awareness

There appears to be a disconnect within multinational corporations about compliance with China’s new law. Executives based outside China are often unaware of the data being submitted by their China-based counterparts, highlighting a gap in corporate policy and risk management strategies.

The Future of the Law

While companies may currently find loopholes to avoid disclosing critical vulnerabilities, there is no assurance that the Chinese government will not tighten its regulations in the future to close these gaps.


China’s vulnerability disclosure law places technology companies in a complicated position. Firms operating in the country must now balance compliance with Chinese law against the security interests of their global customer base and the broader implications for international cybersecurity.