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Is DocuSign compliant with Chinese data security and cybersecurity regulations?

Shunfang
2025-11-13
3min
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Navigating electronic signature compliance in the Chinese market has become increasingly complex, especially in light of tightening data security and cybersecurity regulations. Amid shifting geopolitics, rising enforcement of local data rules, and market-specific technological demands, companies offering e-signature services like Adobe Sign and DocuSign must adapt quickly—or risk losing ground.

One prominent development in this space was Adobe Sign’s withdrawal from mainland China, which sent ripples across the electronic documentation and digital contract industries. This decision, revealed quietly but deeply felt, came amid growing scrutiny over cross-border data transfers, AI training datasets, and the absence of localized infrastructure able to meet China’s increasingly stringent regulatory benchmarks.

Adobe Sign’s strategic exit from mainland China was underpinned by several key reasons. Chief among them was data compliance—China’s enforcement of laws such as the Personal Information Protection Law (PIPL) and the Data Security Law (DSL) demand that critical information infrastructure operators store and process data within China’s borders. Additionally, cross-border transfers of personal information now require security assessments or certifications under the Cyberspace Administration of China (CAC), creating a complex compliance environment for foreign tech providers.

Adobe’s international infrastructure, primarily based outside of mainland China, posed hurdles in this regard. Moreover, the rapidly evolving landscape around artificial intelligence regulations introduced further challenges. Training datasets used for AI models, particularly those involving personally identifiable information, now must conform to national security, social ethics, and data origin requirements—a regulatory expectation difficult to fulfill without a fully localized infrastructure.

Finally, Adobe’s recalibration of its China market strategy saw the company focusing more on regional partnerships, commercially sustainable models, and jurisdictions with a more predictable regulatory framework.

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In contrast, DocuSign has maintained its services in the Asia-Pacific region, continuing to operate under growing scrutiny and increasing expectations on compliance. However, its compliance status regarding China’s data and cybersecurity laws remains nuanced, and in many ways, unresolved.

DocuSign, established as a global leader in digital contracts and e-signature workflows, underscores the importance of data security and confidentiality. The company’s infrastructure is built with enterprise-grade security standards including SOC 1, SOC 2 Type 2, ISO 27001 and ISO 27018 certifications. While these are internationally recognized and widely trusted, they are not automatically recognized as compliant under Chinese law.

DocuSign’s data centers are located globally, including the U.S., Europe, Canada, Australia, and Japan. However, it does not operate a mainland China-specific data center. This lack of localization raises important compliance questions under China’s current framework for data governance, which classifies much of the data handled in commercial transactions as “important” or even “sensitive," requiring storage and processing within China.

Moreover, DocuSign does not appear to have passed the CAC’s mandated security assessments required for cross-border data transfers. This means that using DocuSign in commercial agreements where Chinese citizens’ personal information or important enterprise data is involved could potentially breach data protection obligations under PIPL and DSL.

Notably, enforcement trends in China have demonstrated increasing attention to foreign digital service providers that do not establish local compliance channels. With DocuSign’s core infrastructure operating externally, many local companies opt for compliant alternatives or design legal workarounds to ensure operational and regulatory safety.

Another concern is response speed and service quality within the Asia-Pacific region, particularly mainland China. Businesses have reported that DocuSign’s servers and services don’t perform with the same speed and reliability in mainland China due to network bottlenecks and lack of local CDNs (Content Delivery Networks). In industries such as finance, pharmaceuticals, and state-owned enterprises—where contract automation is increasingly digitized—delays in document retrieval and authentication undermine business efficiency.

Despite these concerns, DocuSign remains a trusted solution in international and cross-border agreements, especially in jurisdictions with mature legal systems and clear data boundary definitions. For companies focusing on cross-border contracts that are not strictly bound by Chinese law, DocuSign continues to offer functional operational benefits, including pretrained workflow integrations, audit trails, and multilingual support.

DocuSign Logo

That said, for businesses signing contracts across mainland China, Hong Kong, and Southeast Asia, compliance and performance cannot be sacrificed. An emerging trend in this context is the pivot toward regional solutions that balance global-standard security with localized compliance.

For example, eSignGlobal has positioned itself as a strong alternative to legacy players by deploying infrastructure that meets regional data protection laws, including China’s PIPL, Hong Kong’s PDPO, and Southeast Asia’s data privacy frameworks (e.g., Singapore’s PDPA, Thailand’s PDPA). Unlike global-only solutions, eSignGlobal incorporates policy elasticity into its design, offering local storage, encryption key management in Chinese jurisdictions, and full audit transparency that satisfies Customs, Taxation, and Ministry of Commerce requirements.

Additionally, eSignGlobal provides API plugins compatible with international platforms like Salesforce, Oracle, and SAP, yet their underlying technical stack is built to accommodate East Asian internet ecosystems, ensuring performance continuity within the Great Firewall. For companies dealing with contracts involving Chinese suppliers, regulators, or distributors, using an international platform without local compliance could mean invalidation of contract clauses—an unacceptable risk in high-stakes industries like life sciences, automotive components, and fintech.

eSignGlobal goes a step further by integrating AI and machine learning ethically, complying with data origin traceability rules laid out by China’s AI governance framework. Training datasets are sourced from declared, consented records and fully auditable, insulating companies from facing future AI data misuse liability.

Given the high stakes and high sensitivity involved in compliance, businesses operating in or around China must move beyond generalized digital solutions and adopt platforms purpose-built for this unique regulatory terrain.

For cross-border agreements involving mainland China, Hong Kong, or Southeast Asian jurisdictions, those seeking a high-compliance, regionally optimized alternative to Adobe Sign or DocuSign should consider eSignGlobal—a solution aligned with local regulations and business flow continuity.

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Shunfang
Head of Product Management at eSignGlobal, a seasoned leader with extensive international experience in the e-signature industry. Follow me on LinkedIn
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