China’s new rules governing exit and entry intermediaries are now in force, bringing immigration and emigration agencies back under a national filing system eight years after the country abolished its previous licensing regime.
The changes took effect on September 15, 2026, under State Council Order No. 841, which introduced a wider set of rules covering Chinese citizens leaving the country, foreigners entering China, and businesses providing exit and entry intermediary services.
The day before the new framework took effect, the National Immigration Administration, or NIA, and the State Administration for Market Regulation published detailed filing measures setting out how intermediary companies and their personnel must register.
The filing system is therefore no longer a future proposal. It is operational, with official forms published and local immigration authorities responsible for receiving filings. Existing businesses have been given a transition period to comply.
China Is Reintroducing Oversight After Eight Years of Deregulation
China began requiring private exit and entry intermediary agencies to obtain operating licenses in 2001. That licensing requirement was abolished in 2018, after which the number of businesses entering the sector increased significantly.
An incomplete government count showed that, as of June 2026, more than 160,000 entities had “private exit-entry intermediary services” included within their registered business scope. The figure does not mean China has 160,000 active immigration agencies, but it illustrates how widely the activity has spread since deregulation.
The Ministry of Justice has said the sector now includes traditional immigration and study-abroad agencies as well as overseas employment businesses, law firms, travel agencies and other organizations offering exit and entry-related services.
Authorities also identified problems including misleading advertising, false documentation, inadequate professional expertise, companies operating without appropriate premises or personnel, and some overseas organizations soliciting mainland clients through online and remote-sales channels.
The new rules do not restore the old licensing system exactly as it existed before 2018. Instead, China has introduced a filing system combined with ongoing regulatory supervision.
Which Businesses Must Register?
The filing measures define exit and entry intermediary services as paid activities in which an organization accepts instructions from a client and provides services connected with tourism, business, study, employment, settlement or similar cross-border activities.
Covered services include policy consultation, assistance with documents and the handling of exit and entry procedures.
Nonprofit policy consultation and general information inquiries are not treated as intermediary services under the framework.
This means the rules extend beyond companies that identify themselves specifically as immigration agencies. The nature of the services being provided, whether the company is acting for a client and whether it charges for those services are all relevant.
Existing Agencies Have 90 Days to File
Businesses already providing covered services before September 15 have 90 days from the effective date to complete their filing.
Newly established intermediary businesses must file with their local immigration authority within 15 days of establishment. Where an existing company begins providing covered intermediary services later, it must file within 15 days of starting those activities.
The filing requirement extends beyond the company itself. The organization must also complete filings for its legal representative or person in charge, management personnel and employees who directly provide exit and entry intermediary services.
Branches operating in different jurisdictions must complete the relevant filings locally.
Agencies Must Show They Have the People, Premises and Systems to Operate
The rules set minimum operating conditions for businesses entering the filing system.
An intermediary must be legally established, and its legal representative or person in charge must not have been criminally punished for an intentional offense.
The company must also have employees with appropriate knowledge of exit and entry laws, regulations and policies, together with funding and premises appropriate to the activities it conducts.
Employees directly providing intermediary services are subject to additional criminal-record requirements relating to offenses involving national security, public security and border administration.
Companies must also maintain formal systems covering employee management, professional education and training, document retention, data security and compliance management.
One point is particularly important because it was uncertain when the regulations were first announced: the final rules do not establish a fixed RMB minimum capital requirement or mandatory security deposit.
Earlier market commentary suggested that China could revive a deposit system similar to the one used under the old licensing regime. The final September filing measures do not do so.
Overseas Relationships Must Be Documented
For agencies providing outbound intermediary services, the September filing measures require additional evidence concerning their overseas relationships.
The filing must include a cooperation agreement or valid letter of intent with the relevant overseas service organization, together with information explaining the cooperation relationship.
This is likely to be particularly relevant to international immigration firms, investment migration providers and overseas professional services businesses that obtain mainland Chinese clients through domestic partners.
The new system gives regulators greater visibility not only over the Chinese intermediary but also over the overseas organizations with which it works.
Overseas Companies Cannot Directly Provide Intermediary Services Inside China
Another important provision affects international firms operating in the Chinese market.
The State Council rules state that overseas enterprises and institutions may not provide exit and entry intermediary services within China.
However, this does not mean foreign-owned companies are excluded from the market.
China’s Ministry of Justice has clarified that foreign-invested enterprises legally established within China may provide intermediary services in accordance with the rules. The same applies to legally established enterprises funded by investors from Hong Kong, Macao and Taiwan.
The distinction is therefore between an overseas entity directly conducting intermediary business inside China and a legally established entity operating within China under the domestic regulatory framework.
That distinction matters for international companies that market or sell immigration-related services directly to mainland Chinese clients, including through online and remote-sales channels.
Advertising, Documentation and Client Handling Face Tighter Controls
Filing is only one part of the framework.
Intermediaries are prohibited from publishing false information or using exaggerated or misleading advertising to attract clients.
They may not provide or assist in providing false materials, improperly help clients obtain visas, residence documents, passports or other exit and entry documentation, or unlawfully disclose or sell personal information.
Companies must also maintain service records and client files documenting the client, services provided and the outcome of the work. Contracts, personal information, financial documents and other relevant records must be retained for regulatory inspection.
Changes to relevant filing information must generally be reported within 15 days.
Authorities can supervise businesses through inspections, complaints and information sharing between immigration authorities, market regulators and other government departments.
Public Officials and Military Personnel Receive Specific Treatment
The regulations also address services provided to Chinese public officials and military personnel.
Intermediaries may not improperly assist such individuals in obtaining foreign nationality, overseas permanent residence, foreign residence documentation or other exit and entry documents or procedures.
Where a request involves the improper handling of such matters, the intermediary must refuse the service and report the case to the relevant supervisory authorities.
This is one of the areas where the new framework goes beyond ordinary consumer-protection rules and connects intermediary supervision with wider state security and public-sector controls.
The Filing Rules Form Part of a Broader Exit and Entry Overhaul
The September 15 changes are not limited to immigration and emigration intermediaries. State Council Order No. 841 forms part of a wider overhaul of China’s exit and entry administration, covering both Chinese citizens leaving the country and foreign nationals entering it.
For Chinese citizens, the framework sets out clearer grounds and procedures for exit restrictions in specified circumstances, including certain document and border violations, conduct overseas affecting national security or national interests, and some export-control or technology-related violations.
The regulations also formalize China’s approach to high-risk destinations. Immigration authorities may warn citizens planning to travel to countries or regions carrying the highest security-risk classifications and, where necessary, discourage them from making the trip.
These provisions sit alongside the new intermediary filing regime, showing that the September framework is broader than agency registration alone. It combines tighter supervision of service providers with more formal rules governing cross-border movement itself.
Article 6 Allows Written Notice to Be Withheld in Certain Cases
Article 4 of the new regulations sets out several circumstances in which Chinese citizens may be prevented from leaving the country.
A citizen who receives administrative detention for fraudulently obtaining exit or entry documents, or for illegally entering or leaving the country, may be barred from departure for between six months and three years after the penalty has been completed.
Chinese citizens who engage in unlawful or criminal conduct overseas that harms China’s national security or national interests may face the same six-month-to-three-year restriction after returning to China.
A separate ground applies where a Chinese citizen violates export-control or technology import-export rules in a way that could endanger industrial or technological security. In those cases, the relevant commerce or other competent authorities may impose an exit restriction. Unlike the other two categories, the regulation does not specify a fixed time limit.
Article 6 also sets out how individuals are normally informed of an exit restriction. The deciding authority must generally notify the person in writing of the facts, reasons, legal basis and available avenues for redress.
However, that written notice may be withheld where providing it could affect national security, a criminal investigation or other circumstances specified by law. When immigration authorities enforce the restriction, they must inform the individual in accordance with the information provided by the deciding authority.
The regulations also strengthen warnings for travel to high-risk destinations. Immigration authorities may advise citizens to exercise caution and, where a destination carries the highest risk level or presents serious threats to personal safety, may discourage them from traveling there.
A warning or discouragement on its own does not amount to an exit ban.
These provisions should not be described as a general restriction on Chinese emigration. Instead, they establish specific circumstances in which an individual may be prevented from leaving the country and clarify how those decisions are communicated.
Rules for Foreign Nationals Are Also Becoming More Formalized
The regulation simultaneously introduces additional consequences for foreign nationals who provide false information.
A foreign national who provides false materials or makes false statements when applying for a Chinese visa overseas or seeking entry at the border can face a one-to-five-year entry ban.
Similar restrictions may apply following certain criminal or administrative penalties involving border management, fraudulent travel documents or illegal entry and exit.
The rules also provide for immigration authorities to implement restrictions involving individuals or entities placed on Chinese countermeasure or unreliable-entity lists.
Immigration and visa authorities can also request documents, information and electronic data when verifying a person’s identity and stated reason for travel, and applicants are required to cooperate.
At the same time, China continues to expand easier entry for ordinary international travelers.
In the first half of 2026, China recorded more than 17.8 million visa-free entries by foreign nationals, up 30.6% year over year and representing 77.7% of all foreign entries.
China’s 240-hour visa-free transit program has also continued to expand. As of August 20, it covered nationals of 57 countries entering through 65 eligible ports across 24 provincial-level regions.
The policy permits activities including tourism, business, visits and family visits, while employment, study and journalism still require the appropriate authorization.
The direction is therefore not simply toward tighter borders. China is simultaneously facilitating short-term travel while applying more formal controls to regulated activities and intermediary businesses.
Violations Can Lead to Fines and Suspension
Businesses that fail to meet their filing or operating obligations can initially be ordered to correct the problem.
Continued noncompliance can lead to fines, suspension of the relevant business and, in serious cases, consequences for the company’s business registration or license.
More serious prohibited conduct can carry substantially higher penalties.
Where illegal income reaches RMB 20,000 or more, authorities can confiscate the proceeds and impose a fine of between one and five times the illegal income.
Where there is no illegal income or it is below RMB 20,000, fines can range from RMB 20,000 to RMB 50,000.
Responsible managers and other directly responsible individuals can also face separate penalties.
A National Filing Information Platform Is Being Established
The NIA has said it will establish a nationally unified filing-information disclosure platform on its website containing information on registered intermediary organizations and personnel.
The underlying filing system is already operational, and the NIA published the official filing forms when the system came into effect on September 15.
However, the national public disclosure platform should be distinguished from the filing system itself.
The NIA’s September 14 announcement described the nationwide platform as something it would establish, so it would be premature to describe a fully populated national public register as already operational.
What Changes for the Immigration Industry?
For Chinese intermediaries, the immediate change is straightforward: businesses that fall within the definition of an exit and entry intermediary can no longer operate in the relatively lightly regulated environment that followed the abolition of the licensing regime in 2018.
They now face formal filing requirements, personnel registration, minimum operating conditions, recordkeeping requirements, advertising controls and ongoing regulatory supervision.
For overseas immigration firms, the implications are different.
The rules expressly prevent overseas entities from directly conducting intermediary services inside China while requiring Chinese outbound intermediaries to document their relationships with overseas service organizations.
That places greater importance on how international providers structure their activities in mainland China and how relationships with local intermediary businesses are documented.
What cannot yet be stated with certainty is how much the new framework will reduce the number of firms operating in the market, whether Chinese applicants will shift more of their advisory activity offshore, or which regional markets might benefit from any redistribution of business.
Those are possible market consequences, but the rules themselves do not establish them.
What is already clear is that China’s immigration-services market entered a different regulatory phase on September 15, 2026.
Eight years after removing the old licensing requirement, Beijing has brought intermediary businesses and their personnel back within a formal national oversight system, this time through filing, disclosure and continuing supervision rather than a return to the previous licensing model.
