A seasoned veteran of the Chinese RCBI market keeps readers abreast of overarching trends in the world’s biggest investment migration market.
On July 22, Premier Li Qiang signed the State Council decree promulgating China’s new regulations on exit and entry administration. The rules take effect on September 15, 2026.
Emigration agents must go back on a register, reversing the 2018 deregulation, so I will not re-litigate the text here. What I want to set out instead is what the rules will actually do to behavior: whose behavior changes first, which business models stop working, and where the demand goes when it leaves.
Because the answer, I think, will surprise the people currently reading these rules as the end of the Chinese market. They are not that. Read properly, they are a redistribution of it.
First, the part nobody in our market is talking about enough: Border control is now institutionalized
Most of the commentary I have seen focuses on the agent register. But the provisions that will move client psychology fastest are the ones aimed at Chinese citizens leaving the country. For the first time, the regulations set out the grounds for restricting exit systematically rather than leaving them to case-by-case application.
Four categories matter. Nationals who commit offenses abroad that are judged to endanger national security or national interests can be barred from leaving for six months to three years after they return. Those penalized for document fraud or illegal exit and entry face a ban of the same length.
Breaches of export control and technology import-export rules that may endanger industrial or technological security form a third ground, and there the text sets no time limit. Read that one, in practice, as aimed at people in AI and semiconductors. And the authorities will actively discourage travel to countries rated highest-risk.
None of this is a bar on emigration. But it does not need to be.
What it produces is a sense among high-net-worth Chinese that the exit is being narrowed, and in my three decades in this market I have never seen that sensation reduce demand. It accelerates it. Perceived scarcity of the exit is the single most reliable driver of urgency our market has.
Second, foreigners get a stricter door and a wider one at the same time
For foreign nationals, the compliance threshold goes up. Supplying false information can now earn a one-to-five-year entry ban. Anyone on a countermeasure list or the unreliable entity list can be refused.
Immigration officers may demand electronic data, and travelers are under a duty to cooperate.
Yet the facilitation push runs in parallel and is, in volume terms, far larger: 240-hour visa-free transit, expanding visa-free entry, and 17.8 million visa-free foreign arrivals in the first half of 2026, up 30.6% year on year. China remains one of the most restrictive immigration destinations in the world while opening the tourist tap as wide as it will go.
There is no contradiction here once you separate the two things Beijing is doing. Tourists bring economic and reputational returns at no regulatory cost.
Bankers, insurers, migration consultants, lawyers, and accountants are a different matter. This is the point international firms need to absorb: A tourist visa has never been, and now emphatically is not, a lawful basis for selling to Chinese clients on Chinese soil. The new framework keeps exactly that category of visitor outside the market.
Third, the register will thin the field, and worry the clients more than the agents
Agencies and individuals providing exit-entry intermediary services must now file with the authorities. To do so they need to be lawfully registered with those services in their business scope; their legal representative, principals, and service staff must be free of relevant criminal records; and they must hold premises and capital proportionate to the business. That last condition looks to me like a revival of the deposit regime introduced in 2001, and my expectation is a figure somewhere between RMB 1 million and RMB 5 million.
Two further provisions carry more weight than their length suggests. Intermediaries may not improperly arrange foreign nationality or permanent residence for public officials or military personnel, and must report such cases if they encounter them. And overseas entities may not conduct exit-entry intermediary business inside China directly.
Every filed agent becomes a reporting node under the first. The second closes the direct-selling route that international firms have been drifting toward since 2018.
Numbers of firms and licensed practitioners will fall sharply. But the more consequential effect is on applicants: A filed agent is a visible agent, and Chinese clients have never been more sensitive about who can see their file. Registration does not frighten agents nearly as much as it frightens their customers.
So does the market revert to the pre-2018 B2B model?
Clients ask me this more than anything else, and my answer is no. A return to the old arrangement (foreign migration program providers handle the destination government regulations and the investment, Chinese agent finds the client and prepares the paperwork) is unlikely, because the model was built for a market that no longer exists. The consumer now leads China’s investment migration market, and what that consumer buys is problem-solving capacity, not application processing.
Look at what has actually grown here over the past five years: tax planning firms, offshore structuring outfits, and cross-border corporate advisers. They treat migration as one tool inside a broader overseas solution. My expectation is that these firms will sign introducer agreements with foreign program providers rather than migration service contracts, capturing the economics while staying outside the filing regime and its costs and exposure.
That is not a loophole but a description of where the value already sits.
And the clients will travel to reach their advisers
Firms operating compliantly inside China will find their permitted scope narrowing toward residence permits and long-term visas, with clearer limits on whom they may serve. Citizenship planning does not fit comfortably inside that box. So a substantial body of applicants will go abroad for advice.
The immediate beneficiaries are in Asia. Hong Kong, Thailand, Malaysia, and Singapore already hold large populations of Chinese nationals sitting on long-term visas who have never taken the second step into citizenship planning.
Add the mainland demand now looking for an offshore adviser, and the migration firms in those four jurisdictions are the ones who will collect the dividend from a Chinese regulation.
Which is the pattern worth remembering every time Beijing tightens this market. Demand does not disappear. It relocates, and it usually relocates to whoever was standing closest to the door.
