Zscaler Services in China - Frequently Asked Questions (FAQs) regarding compliance

Disclaimer:  While this site is designed to address FAQs for Zscaler Services in China, the information contained herein is provided “as is”, and may not be construed as legal advice and organizations should consult with their own legal counsel regarding  their unique obligations under China’s laws and regulations, as all liability with respect to actions taken or not taken based on the statements below is hereby expressly disclaimed. 

• China Premium Access is based on our Chinese technology partners’ IP backbone which passes all domestically and internationally bound traffic through the Great Firewall. Our technology partners have registered on Zscaler’s behalf all IP addresses assigned to the China Premium Access service under China’s Internet Content Provider (ICP) scheme.
   
• China Premium Access Plus connections utilize a dedicated cross-border private link which is registered by our Chinese technology partner with the relevant Chinese government agencies via the three main Chinese telecom companies (China Telecom, China Unicom, and China Mobile). The Chinese Ministry of Industry and Information Technology (MIIT) accepts the use of VPNs for cross-border communications and connections to outside mainland China for business purposes.
   
• However, it is ultimately the responsibility of the end user customer to ensure their own compliance with all applicable Chinese laws and regulations when using the Zscaler Services.
   
• Please see the dedicated site for more information about the Zscaler China Premium Access and China Premium Access Plus services.
   

• Zscaler uses data centres providers in China who hold MLPS certifications.  We do not believe that Zscaler is required to be certified under this scheme as it is mainly intended for vendors that provide information systems and content distribution networks in China.

• Yes, Zscaler complies with the China Personal Information Protection Law (PIPL). For further information, please refer to Zscaler and China’s Data Protection Laws.

• We do not believe that Zscaler is required to obtain an ICP license as our technology partners have obtained the ICP licenses on our behalf. Further, Zscaler's technology partners have made the necessary filings with MIIT for Zscaler's clouds that allow them to be used in China while complying with MIIT's requirements.

• The cross-border link is only provided by the three main Chinese telecom companies that possess the ICP A14-4 license needed to provide this service. Zscaler's technology partner in China will register the customer private link provided under China Premium Access Plus to the main telecom companies on their behalf. This license is not required for China Premium Access as there is no cross-border link to be registered.

• Zscaler has obtained the Network Security Specialized Product Security Testing Certificate (网络安全专用产品安全检测证书) issued by the Computer Information System Security Product Quality Supervision and Inspection Center under the Ministry of Public Security. The certification confirms that the Zscaler Zero Trust Exchange (ZTE) Platform has completed the applicable security testing requirements under the Cybersecurity Law of the People’s Republic of China.

• Zscaler’s white paper regarding our position in China  
• Detailed information about Zscaler’s China Premium Access and China Premium Access Plus offerings