Legal information

Starting from July 1, 2026, the National Energy Administration will officially implement the "Energy Industry Data Classification and Grading Guidelines". This document may seem boring, but it means one thing to everyone working in the energy industry - you finally no longer have to guess how sensitive your data is.

Lawyer Ying Ting analyzed this document and found that this guideline has three biggest benefits for enterprises. First, the classification and grading standards are unified across the country for the first time, ending the chaotic situation of different standards for enterprises in various places. Second, data is divided into three levels: general, important, and core. The data used daily by most enterprises is general data, and the management threshold is not high. Third, and most importantly, desensitized data can be downgraded. Enterprises are fully capable of downgrading highly sensitive data through technical means, thus significantly reducing compliance costs.

The question is, which data will be classified as important or even core level?

The guidelines give very specific quantitative criteria. For example, the geographical coordinates of nuclear power plants and the precise location data of substations above 750 kV are all important data. For another example, the raw consumption data of super important power users for more than one consecutive year, and the consumption data of users with levels above 100 million, may be identified as core data.

Companies must defend these red lines, but the clarity of the red lines is a boon in itself. In the past, many companies over-protected their data due to uncertainty and were afraid to use or circulate their data. Now that the rules are here, companies can accurately judge what should be protected and what should be circulated with confidence.

Of particular note is the downgrade mechanism. The guidelines clearly stipulate that core data must beDesensitization treatmentLater, if the restore cannot be restored, it can be downgraded to important data or general data. The same goes for important data. This means that enterprises can use data desensitization, statistical analysis and other means to maximize the value of data under the premise of compliance.

There is also room for flexibility in derived data. For the derived data after processing of important and core data, only those that can be restored to the original level will be managed according to the original level. Enterprises doing data analysis, business intelligence, and user profiling are basically within this security range.

Well, if this guide could be summed up in one word, it would be certainty.

The flow of data in the energy industry has been stuck in compliance uncertainty. Party A is afraid of violating regulations, Party B is afraid of stepping on the line, and data cooperation cannot be promoted. Now that national standards have come out, the classification dimensions have been refined from energy types to energy activities, and companies can grade their own data by comparing them. Unified standards have broken down industry barriers, and data will flow more smoothly among power generation companies, power grid companies, and energy technology companies.

The transition period is also fully provided. Effective July 1, enterprises have enough time to sort out their data assets and establish a hierarchical management system. For small and medium-sized energy companies, this is an opportunity to overtake them in a corner - they do not need to start from scratch and can quickly build a compliance framework by directly benchmarking against national standards.

Of course, compliance costs still have to be invested. But thinking about it from another perspective, instead of spending a lot of energy responding to regulatory inquiries and customer reviews every year, it is better to build the grading system once and for all, and then just implement it according to the standards. In the long run, this account is very cost-effective.

The energy industry is in a critical period of digital transformation. Data is a new factor of production, but the premise is that the data can be used and flowing. The point of this guide is not to limit, but to free. It gives enterprises a reassurance and lets everyone know what can be done, what cannot be done, and how to do it safely.

Take action quickly and sort out your company's data assets according to the guide. Only when compliance is done well can the value of data be truly released.

The following is the full text of the document

Energy Industry Data Classification and Grading Guidelines (2026 Edition)

Chapter 1 General Provisions

Article 1In order to standardize data processing activities in the energy industry and strengthen the classification and hierarchical management of data in the energy industry, this guideline is formulated in accordance with the "Energy Industry Data Security Management Measures (Trial)" and other relevant regulations.

Article 2This guideline applies to the classification and grading of non-confidential data in the energy industry within the territory of the People's Republic of China.

When energy data processors carry out energy industry data processing activities that involve state secrets or that are state secrets after aggregation and association, they should abide by the provisions of the Law of the People's Republic of China on the Protection of State Secrets and other laws and administrative regulations.

The definitions of terms in this guide are consistent with the "Energy Industry Data Security Management Measures (Trial)".

Article 3The classification and grading of energy industry data follows the following principles:

The basis is clear. The characteristics and uses of the data are used as the main basis for classification, and the importance and scale of energy facilities and users, as well as the degree of possible security risks, are used as the basis for data classification.

The boundaries are clear. All energy industry data have certain categories and levels, and have corresponding protection measures to facilitate energy data processors to determine the data level.

Just be strict. When energy industry data involves multiple aspects of security risks, the level is determined based on the highest level of risk.

Dynamic updates. When the factors that determine the level of data in the energy industry change, the identification rules and data levels will be adjusted accordingly.

Chapter 2 Energy Industry Data Classification and Grading Rules

Article 4The energy industry data classification dimensions include but are not limited to energy varieties, energy activities, etc.

According to energy types, the primary classification of energy industry data is divided into: coal, oil, natural gas, nuclear energy, hydro energy, wind energy, solar energy, biomass energy, geothermal energy, ocean energy, electricity, hydrogen energy, etc.

According to energy activities, the secondary classification of energy industry data is divided into: planning, design, construction, production, storage and transportation, consumption, scientific research, etc.

Data processors in the energy industry can conduct three- and four-level classifications based on data content and characteristics.

Article 5Based on factors such as data importance, accuracy, scale, and security risks, energy industry data is divided into three levels: general, important, and core.

Article 6Derivative data generated by processing activities such as statistics, association, mining or aggregation of important data and core data in the energy industry, if it can be restored and restored to important data and core data, will in principle be managed at the original level.

Article 7If important data and core data in the energy industry cannot be recovered or restored to important data or core data after desensitization, core data can be downgraded to important data or general data, and important data can be downgraded to general data.

Chapter 3 Important Data and Core Data Identification Rules in the Energy Industry

Article 8The following geographical coordinate data of energy infrastructure with an accuracy better than (inclusive) 100 meters, as well as any data containing this coordinate data, are important data for the energy industry:

Coal mines with an output of 10 million tons/year and above;

Thermal power stations with a single unit (set) capacity of 1 million kilowatts and above and a total installed capacity of 3 million kilowatts and above;

Hydropower stations with an installed capacity of 1.2 million kilowatts and above or a total reservoir capacity of 1 billion cubic meters and above (excluding pumped storage power stations);

nuclear power plants;

Substations (switching stations) and converter stations above 750 kV (not included).

Article 9The following real-time command data of energy infrastructure production and operation are important data for the energy industry:

Hydropower stations with an installed capacity of 1.2 million kilowatts and above or a total reservoir capacity of 1 billion cubic meters and above (excluding pumped storage power stations);

Substations (switching stations) and converter stations above 750 kV (not included);

National Pipeline Network GroupOil and gas control center dispatch control system.

Article 10The following electricity consumption data are important data for the energy industry:

Raw power consumption data of particularly important power users;

Raw power consumption data of first- and second-level important national defense and military power users;

Raw electricity consumption data for 10 million or more electricity users.

Article 11Important data in the energy industry that meet the following conditions are core data in the energy industry:

Raw power consumption data of super important power users for one consecutive year or more;

Raw electricity consumption data for 100 million or more electricity users.

Chapter 4 Supplementary Provisions

Article 12The term “power users” as mentioned in this guide refers to the end consumers who receive power supply from power supply companies, including individuals, enterprises, institutions and other entities.

The so-called special, first-level, and second-level important power users in this guide are identified in accordance with relevant national documents and procedures.

The information referred to in Article 8 of this Guide includes but is not limited to: planning information, design drawings, construction drawings, production operation and maintenance information, and scientific research information.

Article 13In addition to the clear data classification and identification rules in this guide, if other energy industry data are evaluated and determined to be important data or core data in the energy industry, the National Energy Administration will issue supplementary regulations and revise this guide in a timely manner.

Article 14This guideline is interpreted by the National Energy Administration.

Article 15This guideline will be effective from July 1, 2026.