Global data governance at a turning point? Rethinking China-U.S. cross-border data flow regulatory models

China and the United States have traditionally represented the ‘security paradigm’ and ‘freedom paradigm’ in their regulatory approaches to cross-border data flow. However, with the introduction of new rules governing these flows in both countries, this article challenges that perspective and explores the potential implications of this shift for global data governance. Specifically, it analyzes how the recent regulations in China and the United States serve as critical turning points affecting the transition between these paradigms, focusing on the overall regulatory frameworks and institutional developments in both nations. The article provides legal, institutional, and case-based examples to illustrate these changes. Furthermore, it offers a comparative analysis of the existing models for cross-border data flow regulation between China and the United States. Targeted compliance advice is provided for multinational corporations and other businesses frequently engaging in international operations that may be impacted by these regulatory changes. This research aims to deliver comprehensive insights into the latest regulatory developments in both countries and their existing models for cross-border data governance, thereby assisting enterprises in developing effective compliance strategies in practice.