From Resource to Asset: Legal Effect and Value of Data Property Registration System
2026-10-08   |   发布于:赛立信

On September 21, 2026, the National Data Administration announced that China’s first batch of data property registration certificates had been issued successively. 56 enterprises and institutions obtained valid proof of their right to hold, use and operate data. The recipients cover state-owned enterprises, public institutions and private enterprises, spanning more than 10 industries such as healthcare, transportation, information technology and scientific research. Among the 56 certificates, over 15 involve data registered for artificial intelligence application scenarios.

These certificates are generally valid for 5 years and can be registered at data exchanges in Beijing, Shanghai and Shenzhen, applicable to multiple scenarios including data transaction, digital trade, financing guarantee and valuation-based equity contribution.

What Problem Does This “ID Card” Solve?

Professor Sun Yi from the School of Economics and Management, University of Chinese Academy of Sciences, pointed out in a CCTV interpretation that the biggest pain point of data circulation is “not the lack of data, but the reluctance to circulate due to unclear ownership and undefined responsibilities”. The function of data property registration certificates is to turn ambiguous “data property rights” into registrable, verifiable and traceable right certificates, clarifying who holds, who uses, who operates and who benefits.

From “Asset-heavy Operation” to “Data-driven Service”

Shenzhen Airlines is one of the first certified enterprises, holding Certificate No. 001 of the first batch of national data property registrations. According to Yuan Xilin, Chief Information Officer of Shenzhen Airlines, the company has registered property rights for its aircraft maintenance data. Going forward, based on data-derived products, it can provide fault prediction and maintenance solutions to other airlines and airports, promoting the enterprise’s transformation from “asset-heavy operation” to “data-driven service”.

The demonstrative significance of this case lies in: aircraft maintenance data was originally just internal production records of the enterprise, but after registration and right confirmation, it becomes a type of “data product” that can be output externally. Shenzhen Airlines’ role has thus expanded from an airline to a data service provider.

Legal Effect of the Certificate: Not a “Title Deed”, but Stronger Than Ordinary Evidence

A key cognition needs to be clarified: a data property registration certificate is not a “property title deed” in the traditional sense. According to the Guidelines for Data Property Registration Work (Trial) issued by the National Data Administration in July 2026, data property rights are defined as three separate rights: the right to hold data, the right to use data and the right to operate data. The three are independent of each other, and the same right to the same data can be enjoyed by different entities simultaneously. This means registration does not represent exclusive and sole ownership of data, but establishes a corresponding relationship between specific data, specific entities and specific right types.

Legal analysts position it as a type of “strengthened preliminary evidence”. The registration authority shall conduct reasonable and prudent review of the accuracy of data description, source compliance and clarity of property rights; data obtained through illegal or irregular means shall not be registered. It carries more weight than ordinary evidence, but does not yet have the right presumption and public credibility effect of real estate registration.

“Inbound Data Processing” and “Token Transaction”: How Certificates Reduce Trust Costs

The value of data property certificates is particularly prominent in new cross-border data business formats. According to Gu Liang, General Manager of Shenzhen Data Exchange, in new formats such as “inbound data processing” and “token transaction”, enterprises have strong demand for data circulation, but have long lacked corresponding proof of data source and use compliance, resulting in unsmooth circulation. Data property certificates serve as authoritative proof, effectively reducing trust costs between data circulation entities and supporting the operational efficiency of digital trade.

Take “token transaction” as an example: its core scenario is to gather AI resources such as large model APIs, training datasets and data services on a unified platform, measured and settled in tokens. When the compliance of data sources needs to be verified, the data property registration certificate becomes the most direct trust credential.

System Accelerating: National Competition Launched Simultaneously

Five days after the certificate issuance, on September 26, the 2nd “Shuzhitong Cup” Data Intellectual Property Competition was officially launched at the 5th Global Digital Trade Expo. With the theme of “Activating Data Assets, Empowering Industrial Innovation”, the competition focuses on scenario-based innovative utilization, market-oriented circulation and reuse, and legalized right protection of data, aiming to select and cultivate typical application scenarios of data intellectual property.

From the issuance of the first batch of certificates to the launch of a national competition, the institutional channel for transforming data from “resources” to “assets” is accelerating. For enterprises, the most practical action at present is to sort out the source chain and usage scenarios of their own data assets, and evaluate which data have the basic conditions for registration and right confirmation. Only data with clear ownership can enter the channels of transaction, financing and equity contribution.

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