On July 31, 2026, China's State Council released new Regulations on the Administration of Entry and Exit that will standardize and enhance China’s oversight of entry and exit across multiple areas of regulatory concern. U.S. institutions should act now to identify all relevant travel to and from China by institutional stakeholders, evaluate any associated risks, and take steps to mitigate risks. On July 31, 2026, China's State Council released new Regulations on the Admini

On July 24, 2026, the CAC released a Q&A on Cross-Border Data Transfer Security Management that clarifies key compliance expectations. Of particular note, the CAC Q&A emphasizes the need for data minimization in cross- border transfers of job applicant resumes to overseas headquarters or affiliates. On July 24, 2026, the Cyberspace Administration of China (CAC) released guidance clarifying and heightening its compliance expectations in certain cross-border data transfer si

The Shanghai municipal branch of the Cyberspace Administration of China (“CAC”) has fined the online travel agency Ctrip RMB 10 million, citing failure to fulfill cross-border data security assessment obligations and illegal outbound transfer of personal information. This action marks a new escalation in China's enforcement of its data protection laws, including one of the most substantial fines imposed under the PIPL to date. On June 13, 2026, the Shanghai municipal branc

A new NPRM from the Office of Management and Budget (OMB) would significantly reshape federal discretionary grantmaking and allow expanded discretion for the administration to affect its priorities throughout the grantmaking lifecycle. Institutions with programs or collaborations involving China or other countries of concern should assess the potential impact of the proposed regulations now. On May 29, 2026, the Office of Management and Budget (OMB) published a notice of

In early May 2026, criminal threat actors gained unauthorized access to the Canvas LMS and claimed to have exfiltrated 3.65 TB of data. The threat actors issued ransom demands first targeting Instructure, the company that owns and operates Canvas, and then targeting over 300 IHEs. Though the immediate threat against IHEs appears to have been resolved through an “agreement” reached between Instructure and the cybercriminals, affected IHEs should continue to implement their b

On April 13, 2026, the State Council of the PRC published new Regulations to counter foreign sanctions measures it deems to be improper assertions of extraterritorial jurisdiction. The new Regulations could target organizations and individuals who, by virtue of their compliance with foreign sanctions measures, particularly measures that scrutinize the control of Chinese entities, may be accused of implementing such measures. IHEs with research collaborations or academic pro

Litigation based on the use of tracking cookies and similar technologies, brought under various federal and state wiretap and other privacy laws, has increased steadily over the past several years. While most litigation to date has involved for-profit businesses, a proposed class action lawsuit against a non-profit college was recently settled after surviving a motion to dismiss. Colleges and universities should review the tracking cookies and similar technologies installed a

On August 1, 2025, the PRC Supreme People’s Court issued the Interpretation II on Issues Concerning the Application of Law in the Trial of Labor Dispute Cases, which establishes uniform legal standards in several employment situations that have raised questions in recent years, including the employment relationship in affiliation arrangements, foreign employees, double wages, and two consecutive fixed-term contracts. U.S. institutions with an RO or WFOE in the PRC should revi

On September 11, 2025, the Cyberspace Administration of China released the Measures for Cybersecurity Incident Reporting, which clarify the specific requirements for network operators regarding cybersecurity incident reporting. The Measures require network operators to report certain incidents within one to four hours, depending on the type of entity involved. On September 11, 2025, the Cyberspace Administration of China (“ CAC ”) released the Measures for Cybersecurity Inc

Following a December 29, 2025 notice published by the Cyberspace Administration of China, institutions that handle personal information of children in China must report on their handling activities by January 31 each year (starting January 31, 2026); Several recently effective U.S. state comprehensive data privacy laws impact whether/how institutions may engage in targeted advertising to minors; The same U.S. state laws also impact whether/how institutions may “sell” minors’