2026-01-09
New Policy on Data Circulation Service Institutions Implemented as China’s Data Market Enters a Phase of “Stronger Functions and a More Vibrant Ecosystem”
Source:www.cb.com.cn
Recently, the National Data Administration released the Guiding Opinions on Cultivating Data Circulation Service Institutions and Accelerating the Market-Oriented and Value-Based Development of Data Elements (Draft for Public Consultation) (hereinafter referred to as the “Opinions”).
Tan Tianyi, Senior Researcher at the Guangzhou Data Exchange, noted in an interview that the issuance of the Opinions is not a simple summary of existing practices. Rather, it represents a systematic and forward-looking institutional design and roadmap aimed at addressing the most critical bottleneck in the value realization of data elements — obstacles in data circulation. This marks a significant transition in China’s data market development: from the initial “framework-building and platform-establishing” exploratory stage to a new phase characterized by enhanced functionality and a more vibrant ecosystem.
On December 19, 2022, the Opinions of the CPC Central Committee and the State Council on Establishing a Data Base System to Maximize a Better Role of Data Elements were issued, establishing China’s foundational data governance framework across key areas, including data property rights, circulation and transactions, revenue distribution, and security governance. The newly released Opinions serve as a crucial “institutional bridge” between this foundational framework and the concrete practices of building a unified national data market. They serve, on the one hand, as an “operational manual” for implementing the data base system, and, on the other hand, as a “hub project” for activating the unified national data market, while simultaneously forming a set of essential “institutional infrastructure” deployed in parallel with physical data infrastructure construction.
At present, China’s data element market faces several deep-seated structural challenges: high compliance costs and difficulties in establishing trust in data circulation; a mismatch between supply and demand and difficulty in valuing data products; inefficient channels for the socialized development and utilization of public data; and a severe shortage of high-quality “data fuel.”
Tan Tianyi pointed out that the role of data exchanges (centers) goes far beyond their traditional function of improving transaction matching efficiency.
The deeper intention of the Opinions is to promote a fundamental transformation of data exchanges — from mere “trading venues” that provide transaction sites and matching services into “market operators” that establish rules, build trust, and organize the ecosystem.
The smooth functioning of the data element market depends on three key players: data exchanges (centers), data circulation service platform enterprises, and data service providers. In this regard, the Opinions clearly outline an ecosystem in which the three entities maintain distinct focuses while developing in coordination. Accurately understanding their respective core functions and interrelationships is essential to avoiding homogenized competition and to forming a strong collective force for development.
More specifically, the core function of data exchanges (centers) lies in serving as the “market operator” and “cornerstone” of the data factor market, while data circulation service platform enterprises act as “enablers” and “organizers” within their respective vertical sectors.
In Tan Tianyi’s view, the release of the Opinions not only outlines a general development blueprint but also creates strategic opportunities for differentiated development based on regional characteristics. Going forward, data exchanges should anchor their development in a deep understanding of national strategic objectives, a precise grasp of the market’s core pain points, and the full leverage of their inherent strengths. The core value of future leading data trading venues will be reflected in their ability to provide indispensable “certainty” for the large-scale circulation of data elements.
Based on this fundamental mission, the development of data exchanges is expected to evolve toward diversification and specialization. Their central role depends on whether they can identify and solidify their functional role within the broader framework of the unified national data market, thereby addressing deep-rooted market challenges in specific market segments and providing indispensable trust value.

