On September 15, 2026, China’s new filing rules for exit and entry intermediaries take effect. For foreign investment migration providers, the immediate questions are predictable.
Providers want to know which agents will survive, whether the large agencies will recover market share, and whether more Chinese clients will need advice from outside the mainland.
The question that decides more is operational. It is whether the way you recruit and service Chinese investors fits the market these rules arrive in.
China is applying a new regulatory framework to a market that has changed considerably since licensing was abolished in 2018. Hundreds of smaller sources of clients now work alongside the major immigration companies.
Foreign providers support far more distributors than they once did, and they have taken on much more of the marketing, product education and client support themselves. Chinese consumers reach far more information than they could in 2018.
Anyone expecting a return to the pre-2018 market is therefore looking at the wrong place.
2018 Changed Who Could Reach the Client
Before 2018, China licensed its exit and entry intermediaries under a system with substantial barriers to entry. Firms needed prior approval, minimum staffing, premises and a supervised reserve, and most faced geographic restrictions.
The government abolished that system in 2018.
For most of the 2000s and 2010s, foreign providers could concentrate on a small number of important national and provincial agencies. The Chinese agent normally controlled the client relationship, the local marketing and much of the information that reached the consumer.
Physical presence from foreign professionals counted too. Agents expected providers to train their teams, attend meetings, answer technical questions and support sales.
That need for foreign professionals on the ground was one reason I established myself in Hong Kong.
The larger agencies progressively professionalized. They occupied premium offices, built project approval committees and added project directors, sales directors, processing teams, settlement departments and overseas offices.
That institutional sophistication did not always translate into better product selection. Commission, marketability and ease of sale frequently remained decisive.
A sophisticated approval process could identify weaknesses in a product without preventing the agency from selling it.
Since 2018, senior managers and strong consultants from established agencies have opened smaller firms. Wealth managers, lawyers, accountants, private bankers and family office professionals have added immigration to businesses that already reach high net worth clients.
A provider may now work with a professional who produces one or two cases a year and has relationships with another ten prospects.
For foreign providers, this has meant broader coverage, more conferences, more agent meetings, more Chinese marketing material, more technical training and more individual client support.
Large industry gatherings have become important access points to smaller distributors that were previously difficult to reach.
The large agencies remain influential. My own reading is that their direct market share has declined, and that smaller agents watch which projects the major firms accept.
Distribution by a leading agency can provide credibility across the wider market.
So 2018 reduced dependence on large agents without reducing dependence on Chinese distribution itself.
The New Rules Will Reshape the Agent Network
State Council Order No. 841 requires that institutions providing exit and entry intermediary services file with the immigration authorities. Employees come within the same filing framework, through their employer.
A filed firm must have premises and funds proportionate to the work it does, staff who know the relevant law and policy, and internal systems covering personnel, training, record retention, data security and compliance.
Firms already doing this work before September 15, 2026 have 90 days from that date to file.
The government has not restored the former licensing regime. Qi Lixin, who chairs the Beijing Migration and Exit-Entry Service Industry Association, writes in commentary the National Immigration Administration published alongside the regulation that the rules apply filing with ongoing supervision in place of prior administrative approval.
Several barriers that protected the old market have not reappeared. The published rules set no minimum headcount, no reserve equivalent to the former RMB 500,000 requirement, and no restriction confining a firm to its own province.
The detailed filing measures had not appeared at the time of publication, so predictions about how many firms will survive are premature.
Qi describes one-person studios, shared offices, remote selling, and domestic shadow companies set up by overseas institutions. A small number of firms, he adds, have no premises, no professional staff, no funding, no overseas partner and no management system.
On Qi’s count, more than 160,000 entities listed private exit and entry intermediary services in their registered business scope as of June 2026. He calls that count incomplete, and few of them are likely to be meaningful investment migration participants.
Some smaller firms will therefore have to professionalize, cooperate with other institutions or leave regulated intermediary work.
Their client relationships do not necessarily disappear with them.
Smaller Players May Retain the Client Relationship
Many of the newer sources of investment migration business are not traditional immigration agencies.
A wealth manager may meet ten clients with international planning needs and generate one or two immigration cases. The same applies to accountants, lawyers, family office professionals and former immigration consultants.
Some will build the infrastructure they need to file and work independently. Others may decide that a regulated immigration intermediary business is not worth maintaining.
This points to a third market structure. Client sourcing and contracting were both concentrated before 2018, and both fragmented after it.
Once the rules take effect, sourcing may remain fragmented even as compliant contracting and servicing concentrate again.
That would resemble the old subagent model on the surface alone.
Today’s smaller originators know market commissions, deal directly with foreign providers, attend the same conferences as the large agencies and compare products quickly. Their clients reach far more information than they used to.
AI is reducing some of the analytical advantage that once needed a large organization.
A filed intermediary may therefore become more important to the transaction without recovering the information and economic control that the major agencies once enjoyed.
Mid-sized firms could benefit as much as the traditional giants. They may have enough compliance infrastructure and remain more flexible on economics and cooperation arrangements.
For providers, this means that fewer institutions formally servicing cases does not necessarily justify shrinking the distribution network.
The more important question remains who influences the client’s choice of product.
Foreign Providers Need to Review How They Work in China
The new framework creates a more immediate issue for foreign providers.
Order No. 841 bars overseas enterprises and institutions from providing exit and entry intermediary services inside China.
The rules name client-facing work such as policy consultation, document handling and procedural services. They do not yet set out how ordinary business relationships between foreign providers and Chinese agents should be treated.
Providers should therefore avoid two extremes. Assuming that every post-2018 practice can continue unchanged would be careless.
The opposite conclusion, that foreign providers can no longer do meaningful business in China, goes further than the published rules support.
Every provider active in China should now be able to name, for each case, who sourced the investor, who advises that investor on the immigration solution, and who contracts with the investor and services the file.
These questions force management teams to distinguish product support from direct immigration intermediary activity without pretending that the final legal boundaries have already been settled.
Training agents, presenting a project privately to an intermediary, negotiating commercial arrangements and supplying project information fall on a different side of that line from soliciting mainland consumers directly and advising them on immigration strategy.
Agent supported client meetings deserve particular attention. Foreign providers have long attended them to explain projects, investments and technical features.
Until the detailed measures appear, foreign business development staff working independently with mainland consumers deserve much greater caution.
Marketing requires the same review.
Since 2018, fragmented distribution has pushed providers to produce much more Chinese consumer material. I expect that support to continue.
Public consumer marketing, though, deserves more scrutiny than private material used to educate intermediary teams.
Branding or white labeling does not resolve the underlying issue. The questions are who distributes the material, who receives it, what claims it makes and what role the foreign provider performs.
The Investment Rules Could Reach Even Further
A separate policy development could weigh even more heavily on providers.
China has already brought outbound investment by resident individuals inside its regulatory framework. State Council Order No. 837 took effect on July 1, 2026, and it counts resident individuals as investors alongside enterprises.
That regulation leaves the detailed measures for individuals to the investment and commerce authorities. The National Development and Reform Commission published its revised draft Measures for the Administration of Outbound Investment on August 21, and comments close on September 20.
The draft was not final at the time of publication.
If the current approach survives, certain direct overseas investments by Chinese resident individuals would need a filing notice before the investment is made.
The draft names overseas land, meaning ownership and use rights, and it names the establishment of or an equity stake in an overseas equity investment fund. Its list of qualifying acts is expressly not exhaustive.
Other investment migration structures need their own analysis, on their particular legal and investment characteristics.
For providers, the commercial implication is straightforward.
Chinese agents have historically evaluated products according to immigration attractiveness, investment economics, commission, marketability and provider credibility.
China-side regulatory friction could become another factor.
An attractive immigration program may become hard to distribute if the underlying investment creates substantial compliance friction for a mainland investor. Programs with a simpler China-side investment path may become more competitive.
That could cause demand to diverge among products instead of rising or falling across investment migration as a whole.
The proposal may change substantially before adoption, and providers launching investment products in China should already be watching it.
The Recruitment Model Needs to Change
Too many questions about the detailed measures remain open to predict how many small agencies will survive, how much market share the major firms recover, or how hard the rules get enforced.
The market will also adapt collectively. Industry associations will interpret the measures, major agencies will seek guidance from the authorities, and competitors will watch one another closely.
Once enforcement patterns become visible, behavior should adjust quickly.
Filing does not rewind the market to where it was before 2018.
The client sourcing network is broader than it was, and small originators serving high net worth clients have established themselves inside it. The large agencies retain market making power without controlling distribution as they once did.
Foreign providers have built far deeper sales and marketing support, and Chinese consumers have become more informed and more demanding.
The new rules now land on top of that market.
The work for foreign providers is to redesign how they recruit and service Chinese investors, and to start before the filing deadline closes rather than after it.
Nicolas Laurin is President of Eterna International, based in Hong Kong. To talk through what the new rules mean for your China distribution, contact Eterna International.
