【Purpose/significance】With the arrival of the era of big data, data is becoming the asset to be activated, and thusthe data opening and sharing movement is expedited on a global scale. This paper aims to construct China’s open data poli-cy model in era of big data, explain and predict the policy reality of open data.【Method/process】Referring to the researchperspective on government data opening internationally, and starting from the perspective of public management, this paperexpounds the basic theory of the open data policy system and its model through the methods of content analysis and systemanalysis.【Result/conclusion】Constructing the System-Regime-Process theoretical model of China’s open data policy andits sub-models of demand layer, decision layer and operation layer under the big data environment, and to adjust the exist-ing policy requirements through the operation of two circular paths. The result of the model operation is not necessarily theintroduction of the special policy of open data, which is the essential difference between the"S-R-P"theory model and thegeneral public policy theory model.