China’s State Council has ordered every agency selling emigration, visa, and other exit-entry services to file with immigration authorities, ending a deregulated stretch that began in 2018. Premier Li Qiang signed Order No. 841 on July 22, and the regulation takes effect on September 15.
Nineteen articles cover overseas safety warnings, entry bans on foreign nationals, and the conduct of intermediaries. Only the third of those reaches into the channel serving one of the world’s largest source markets for investment migration.
Who must file, and by when
Article 7 applies filing management to agencies and individual staff retained by travelers and emigrants for exit and entry policy consultation, document handling, procedural work, and other intermediary services. A new agency has 15 days from its establishment to file with the immigration authority where it sits. Personnel file through their employer.
Anyone already providing the services before September 15 gets 90 days from that date, putting the deadline in mid-December. The National Immigration Administration (NIA) is drafting the detailed filing procedure jointly with market regulators and other State Council departments.
Consultation given free of charge sits outside the perimeter. Policy advice and enquiry services provided without a profit motive do not count as intermediary services under the regulation. That reading comes from the Ministry of Justice, the Ministry of Public Security, and the NIA, in joint answers published alongside the text.
Qi Lixin, chairman of the Beijing Migration and Exit-Entry Service Industry Association, wrote in commentary published by the NIA that filing will run mainly online. He also stressed the distinction the drafters are making: this is not a return to pre-approval, but a register plus supervision of conduct after the fact.
Staff, premises, and a documented overseas partner
Article 8 sets out what a filed agency must have. Lawful establishment comes first. The legal representative or person in charge must carry no criminal penalty for an intentional crime.
Staff need working knowledge of exit and entry law and policy, and the agency needs funds and premises proportionate to the services it offers. Employees dealing directly with clients must carry no conviction for an intentional crime against national security, public safety, or border administration.
Internal systems get their own list: personnel management, training, record retention, data security, and compliance. Agencies handling outbound work carry one further condition. They must already have a cooperation relationship with a relevant overseas service institution, or a signed and valid letter of intent.
That condition restores a 2001 requirement rather than inventing one. The Measures on the Administration of Exit-Entry Intermediary Activities for Private Purposes, in force from 2001 to 2018, demanded the same relationship and the same signed letter of intent.
Applicants then had to file it in both languages, together with proof of the foreign partner’s legal standing certified by a Chinese embassy or consulate. Order No. 841 asks for no such certification. It sets no minimum headcount either; the 2001 rules required at least five staff.
The prohibition on overseas firms
Article 8 closes by barring overseas enterprises and institutions from providing exit and entry intermediary services within China. Foreign-invested companies lawfully established in China may still do the work, and so may Hong Kong, Macao, and Taiwan-invested ones. That qualification appears in the joint answers rather than in the regulation itself.
The restriction is less of a departure than it looks. Those same 2001 Measures refused operating permits outright. Overseas institutions, individuals, and foreign representative offices in China could not apply.
What the register is meant to fix
More than 160,000 entities carried private-purpose exit and entry intermediary services in their registered business scope as of June 2026, on Qi’s figure. He described the count as incomplete, and noted that many were set up after the 2018 liberalization.
His account of how some operate is unusually blunt for an association official. Single-person studios, shared desks, and domestic shell companies established by overseas institutions all feature, alongside overseas firms courting Chinese clients through livestreams and remote selling. A minority, he added, have no premises, no qualified staff, no capital, no overseas partner, and no internal systems at all.
Conduct rules and a reporting duty on officials
Article 10 bars filed agencies from publishing false information or drawing clients through exaggerated or misleading promotion. The same article prohibits providing or assisting with false materials, and helping anyone obtain visas, residence permits, or passports in breach of the rules. Leaking, selling, or unlawfully passing on commercial secrets, private matters, or personal information learned during a case attracts the same prohibition.
Working outside the scope an agency has filed is itself a breach. So is organizing or assisting cross-border criminal activity. Item six sweeps in any other conduct that damages national security or interests, or disrupts exit and entry administration.
A separate paragraph addresses public officials, military personnel, and others like them. Where such a client asks an agency to obtain foreign nationality, overseas permanent residence, or an overseas residence permit in breach of the rules binding him, the agency must refuse. It must also report the request promptly to supervisory organs.
Other exit and entry documents and procedures carry the same duty. That duty attaches only where the processing would breach regulations, which points to the separate rules governing officials’ own travel documents and foreign status. Qi framed the clause as tightening the net against officials who abscond with public money.
Fines, suspensions, and revoked licenses
Failing to file, or failing to meet the Article 8 conditions, draws an order to correct within a set period. Refusal brings a fine of RMB 5,000 to RMB 10,000 (approximately US$740 to US$1,480) and notification to the relevant authority to suspend the business concerned or close it for rectification. In serious cases the fine rises to between RMB 10,000 and RMB 50,000 (approximately US$1,480 to US$7,400), with permits or the business license revoked.
Conduct breaches that disrupt exit and entry administration carry heavier exposure. Authorities confiscate illegal gains, and where those gains reach RMB 20,000 (approximately US$2,960) the fine runs from one to five times the sum. Where gains fall below that figure or do not exist, the fine sits between RMB 20,000 and RMB 50,000.
Responsible managers and other directly responsible staff face RMB 10,000 to RMB 50,000 personally. Continued refusal to correct, or serious circumstances, brings suspension, rectification, or revocation of permits or the business license.
Individuals who provide intermediary services in breach of the regulation face an order to stop and confiscation of any illegal gains. Serious cases can carry an additional fine of up to RMB 5,000.
The regime this replaces
Licensing arrived through a State Council notice in 2000. The Ministry of Public Security and the then State Administration for Industry and Commerce gave it shape in Order No. 59 of June 2001. Permits ran five years, carried annual inspection, and required a reserve deposit of at least RMB 500,000, worth roughly US$74,000 at today’s rate.
All of it went in autumn 2018 under the separation of permits from business licenses. From November 10 that year, local exit-entry departments stopped accepting applications, and permits already issued lapsed automatically.
Order No. 152 repealed the 2001 Measures on the same date. Authorities refunded the deposits by the end of that November, and a market entrant thereafter needed nothing beyond a business license.
Researchers counted between 4,857 and 27,238 immigration intermediaries in China the following year, depending on definition, and found 82% of them less than five years old. Those figures rested on company names and business scopes rather than on any register, as does the 160,000 figure cited this year, so the two are not directly comparable.
Exit bans widened alongside
Article 4 adds grounds on which a Chinese citizen may be stopped at the border. Administrative detention for fraudulently obtaining travel documents, or for illegal border crossing, can support a ban of six months to three years. Immigration authorities decide, and the clock runs from the day the penalty ends.
Criminal activity abroad that damages national security and interests carries the same range. That ban runs from the date the citizen returns to China. A competent State Council department decides, or, after verification by diplomatic missions, the provincial government where he is domiciled.
Breaches of export control and technology import and export rules that may endanger industrial or technological security form a third ground. Commerce and other State Council departments decide, and the text sets no time limit.
Under Article 6, the deciding authority must notify the immigration authority to enforce, and tell the individual in writing of the facts, reasons, legal basis, and avenues of redress. That article permits silence where notice may affect national security or a criminal investigation.
What destination-side firms should watch
Program firms and licensed agents abroad carry no filing obligation of their own. Their Chinese counterparties do, and the outbound condition in Article 8 now makes the partnership itself part of the file. Firms that never papered a referral arrangement now have a reason to.
The detailed filing measures have not appeared yet, and they will decide how much of this bites. Until they do, the fixed point is mid-December.
