China reinstates mandatory registration for immigration intermediaries: new rules replace the 2018 easing

The detailed registration procedure is still being drafted: the National Immigration Administration (NIA) is preparing the specifics together with market regulators and other State Council bodies.

At the same time, free consultations are not treated as intermediary services under the registration article. Similarly, information-request services and consultations without profit-making intent are not covered. This interpretation has been clarified through joint responses from the Ministry of Justice, the Ministry of Public Security (Ministry of Public Security), and the NIA.

Qi Lixin, chair of the Beijing Association of the Immigration and Cross-Border Services Industry, said in his view that registration will be largely online. He also emphasized that the change is not a return to the old model of advance approvals, but rather registration followed by ongoing supervision.

Requirements for personnel, office, and overseas partners

Article 8 sets out conditions an agency must meet in order to register.

First, the organization must be legally registered. The person in charge (or the individual responsible for operations) must not have been punished for an intentional criminal offense.

Second, staff must be knowledgeable about laws and policies governing cross-border entry/exit. In addition, employees who directly interact with clients must not have criminal convictions for intentional crimes against national security, public security, or crimes related to border administration.

Third, agencies must maintain internal systems, including personnel management, training, document retention, data security measures, and compliance controls.

For companies that handle overseas cases, there is a key additional requirement: they must have a current partner abroad—either an already established cooperation with a relevant overseas institution, or a signed and effective letter of intent.

Importantly, this condition is not entirely new: it effectively brings back the logic of the rules from 2001. Back then, the “Measures for the Administration of Intermediary Activities for Private Purposes Related to Cross-Border Entry/Exit” also required partner arrangements and a letter of intent.

Under the earlier regime, applicants had to submit documents in two languages and provide proof of the overseas partner’s legal status certified by a Chinese embassy or consulate. Order No. 841 does not mention any requirement for consular certification. It also does not specify a minimum number of employees—whereas the old rules required at least five workers.

Ban on overseas firms operating within China

Article 8 also introduces a restriction: foreign companies and institutions may not directly provide intermediary services related to cross-border entry/exit within China.

At the same time, the interpretation clarifies that foreign companies legally established in the PRC may operate, and structures involving Hong Kong, Macao, and Taiwan are also allowed. This clarification appears in joint guidance rather than in the regulation text itself.

In substance, the restriction is not a complete novelty. In 2001, foreign institutions and their offices also could not apply for permits to conduct intermediary activities.

Why registration is being introduced—and what it is meant to “fix”

According to Qi Lixin, as of June 2026, more than 160,000 organizations had intermediary services for private cross-border entry/exit listed in their articles of association (i.e., in the catalog of registered business activities). He added that the figure is likely incomplete because many players appeared after the 2018 liberalization.

The association’s commentary also criticizes certain operating models. It mentions one-person “studios,” renting workstations without proper infrastructure, and the use of “shell” companies linked to overseas entities. It also highlights the practice of attracting Chinese clients via streaming and remote sales by overseas players.

Qi Lixin further said that, in his view, some participants effectively have no office, no qualified staff, no capital, no overseas partner, and no internal compliance systems.

Rules for intermediary conduct and the duty to report requests from officials

Article 10 prohibits registered agencies from publishing false information or attracting clients through exaggerated or misleading promises.

The ban also covers providing or assisting in the preparation of inaccurate materials, as well as helping obtain visas, residence permits, or passports in violation of applicable requirements. The article separately prohibits the disclosure, sale, or unlawful transfer of trade secrets, personal circumstances, and personal data obtained in the course of a specific case.

It is also considered a violation for an agency to operate outside the scope it is registered for. In addition, agencies are prohibited from organizing or facilitating cross-border criminal activities. The final point of Article 10 covers any other actions that harm national security or interests, or undermine the operation of the cross-border entry/exit administration system.

A separate paragraph establishes a duty for cases where the client is a government official, member of the armed forces, or persons with similar status. If such a client asks the agency to help obtain foreign citizenship, permanent overseas residence, or an overseas residence permit by bypassing the rules applicable to them, the agency must refuse and promptly report to the relevant oversight authorities.

A similar obligation applies to other entry/exit-related documents and procedures—but only when processing would violate the relevant rules. This refers to separate regulations governing travel procedures and the foreign status of officials. In commentary, the condition is described as tightening control over situations where officials abuse state resources.

Fines, suspensions, and revocation of permissions

For failure to file for registration or for not meeting the conditions under Article 8, a remediation mechanism is provided within a prescribed period. If the agency refuses to correct the issue, the fine will be RMB 5,000 to 10,000 (approximately USD 740–1,480) and the relevant authority will be notified of the possible suspension of operations or closure until the violations are fixed.

In serious cases, the fine increases to RMB 10,000 to 50,000 (approximately USD 1,480–7,400), and revocation of the permit or cancellation of registration rights/business license may also follow.

If violations involve actions that break the entry/exit administration order, risks are higher: illegally obtained income must be confiscated. Where income is from RMB 20,000, the fine is calculated as 1–5 times the amount. If income is lower or absent, the fine ranges from RMB 20,000 to 50,000.

Company executives and other persons directly responsible may face an individual fine of RMB 10,000 to 50,000. If they refuse to remedy violations or if there are aggravating circumstances, suspensions, remediation orders, or revocation of permits/cancellation of the business license may be imposed.

Individuals providing intermediary services in violation of the regulation may be ordered to stop business and have illegally obtained earnings confiscated. In serious cases, an additional fine of up to RMB 5,000 may be applied.

What regime the new rules replace

The licensing-style model for intermediary activities was formed through a State Council notice in 2000. Later, the Ministry of Public Security and the then State Administration for Industry and Commerce formalized the process in Order No. 59 from June 2001.

Licenses were issued for 5 years, required annual inspections, and involved a deposit—minimum RMB 500,000 (the author estimates about USD 74,000 at current exchange rates).

In 2018, China began moving toward a model that separated licenses from business licenses. Starting November 10, 2018, local entry/exit authorities stopped accepting applications for licenses, and previously issued permits automatically expired.

Order No. 152 repealed the 2001 measures on the same date. Deposits were refunded by the end of November, and after that, entering the market required only a standard business license.

Subsequent research estimated the number of immigration intermediaries in the range of 4,857–27,238, depending on definitions. It also found that 82% of companies were less than five years old. However, those figures were based on names and business scopes rather than a unified registry, so they cannot be directly compared with the current estimate of 160,000.

Grounds for restricting departure were also expanded

Article 4 adds grounds under which Chinese citizens may be stopped at the border. In particular, administrative detention for obtaining travel documents through fraud or for illegal border crossing can lead to a departure ban for between 6 months and 3 years.

The decision is made by an immigration authority, and the countdown begins from the day the administrative penalty is completed.

A similar time range applies to overseas criminal conduct if it harms national security and interests. In that case, the ban takes effect from the date the citizen returns to China. The competent State Council body makes the decision, either directly or after verification by diplomatic missions—typically the provincial government where the person resides.

The third category concerns violations of export control rules and technology import/export regulations that may threaten industrial or technological security. The decision is made by the relevant State Council departments (the text does not specify the duration of the ban).

Under Article 6, the decision-making authority must notify the immigration authority for implementation and also provide the citizen with a written notice stating the facts, reasons, legal basis, and appeal procedures. “Silence” is allowed if notifying the citizen could affect national security or an ongoing criminal investigation.

What overseas firms and partners should consider

Overseas programs and licensed agents abroad typically do not need to file their own registration. However, Chinese partners must go through the process—and the requirement in Article 8 makes the existence of the partnership itself part of the registration dossier.

Therefore, companies that previously did not put the proper client-referral arrangements in place should revisit their operating model: the new rules create an additional incentive to ensure that partner relationships are properly documented and compliant.

Detailed registration measures have not yet been published. How exactly the requirements are written will determine how tangible they will be for market participants. Still, the “control date” is already set—.