• The centralization concept envisioned for the system is very complex in terms of managing and assuring data quality, data integration and usability. Having lots of data does not guarantee, by a long shot, that useable information, much less insight, can be derived from it.

• More importantly, there is intense institutional and bureaucratic resistance to information centralization and integration at the local government levels and across ministerial verticals. This is a deeply rooted feature of the Chinese political economy and bureaucracy – we’re talking thousands of years of roots. In the Chinese political system, information is power, and agencies and officials typically work hard to sequester information in order to accrue power and protect their interests. It won’t be easy to change this age-old dynamic, even with President Xi’s comparatively powerful hand.

• Building the IT system is not the hard part, nor is commandeering loads of data. These are inputs, and the Chinese government is throwing lots of money at this part of the recipe. Operationalizing the workflows and effecting the collaborations necessary – and the effective sharing and use of information across institutional boundaries – are the hard parts, i.e. the outputs. There is a huge gulf between the two that will take incredible leadership, political will and human capital talent to bridge.

For these reasons, it will likely be some time, if ever, before we see the Corporate Social Credit Score system manifest fully as per the government’s documented statements and plans. In the meantime, claims in state media that the system is or will soon be fully functional serve to provoke self-imposed compliance. Not a bad outcome.

There is, however, a risk that the purported “blacklist” function of the program – something already in the regulatory purview of numerous agencies but now elevated as a regulatory tool by virtue of the Social Credit Score initiative – may be unleashed and more prevalently used in anticompetitive ways. Members should monitor this risk carefully and prepare in advance to respond if/when necessary.