On July 26, 2024, the Ministry of Natural Resources ("MNR") promulgated the Notice of the Ministry of Natural Resources on Strengthening the Administration of Surveying, Mapping and Geoinformation Security of Intelligent Connected Vehicles ("Notice 139"), reiterating the importance of the security of surveying, mapping and geoinformation. This is the second time within a two-year period for the MNR to clarify certain difficulties in the monitoring of surveying and mapping compliance of intelligent connected vehicles ("ICV") and the compliance focus in relation to geographic information data processing following the issuance of the Notice on Promoting the Development of Intelligent Connected Vehicles and Maintaining the Security of Surveying, Mapping and Geoinformation ("Notice 1").

In summary, we believe that Notice 139 does not impose compliance obligations beyond the existing regulatory framework. Compared with Notice 1, Notice 139 puts forward more detailed requirements in terms of the scope of geoinformation data, types of surveying and mapping licenses, and whole-process supervision. However, the compliance obligations are traceable under the existing surveying and mapping laws and regulations.

In this article, we interpret the key compliance points that are closely related to surveying and mapping license holders ("License Holders"), vehicle companies, autopilot companies, and other industry players.