Rules on authorised operation of public data resources: the authorisation chain in data element markets

On 8 January 2025 the National Development and Reform Commission and the National Data Administration issued trial rules on the authorised operation of public data resources, effective 1 March 2025. The interim measures on registration of public data resources were issued in the same period. Together they build a registration-authorisation-operation chain.

Linking three steps

Bringing public data to market requires answering three questions: what the data is, who may use it, and how it may be used. Registration answers “what it is”; authorised operation answers “who and how”. The two documents link the three steps into a relatively complete path.

For AI companies, public data is an important source of training data. The rules mean access to public data has clearer procedures and allocation of responsibility, rather than depending on case-by-case coordination. See our notes on the national public data resource registration platform and on the data property rights registration guide.

The responsibility structure

At the heart of authorised operation is the allocation of responsibility: who is authorised, how wide the scope is, and who bears the security and compliance duties in operation. The trial framing indicates the mechanisms are still exploratory, and local arrangements may differ.

When participating, companies need to look not only at whether they can obtain the data but also at the permitted scope of use, the boundaries of further development rights and the assumption of data security duties. See our notes on the opinion on data circulation service institutions and on the high-quality datasets action plan.

Meaning for training-data supply

The degree to which public data is opened directly affects the availability of AI training data. The rules provide a predictable channel, but they also mean data use will increasingly be traceable and auditable.

For companies this cuts both ways: certainty of access improves, while compliance constraints on use become clearer. See our notes on the National Data Administration datasets guide.

This article is based on the trial rules on the authorised operation of public data resources issued by the National Development and Reform Commission and the National Data Administration and is for reference only; it does not constitute legal advice.