Mandatory reporting is used as a tool for early identification of child abuse by countries around the world. However, there is variation in terms of the legislative models followed. The two models most commonly followed are universal mandatory reporting and stakeholder specific mandatory reporting. India and China joined the bandwagon and introduced legislation on mandatory reporting over a decade ago. While India has adopted the ambitious model of universal mandatory reporting, China has taken a more incremental and experimental approach with stakeholder-specific mandatory reporting. The paper aims to differentiate the legislative approaches taken by the two countries for introducing mandatory reporting for child abuse, by delving into the legislative history, legislative provisions, and implementation challenges for mandatory reporting in both jurisdictions. The paper does not comment on the sanctity of mandatory reporting, but is limited to a comparative analysis of the legislative strategies taken by India and China.

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