China’s new exit and entry regulation entered into force on Monday, widening the grounds on which Chinese citizens can be barred from leaving the country.
Premier Li Qiang signed Order No. 841 on July 22, and its 19 articles now govern everything from overseas safety warnings to the conduct of emigration intermediaries.
Under the rules, citizens can now be barred from leaving for up to three years over conduct abroad that authorities deem “harmful to national security or interests,” while a third category, tied to technology and export controls, carries no stated limit at all.
Three New Grounds for Exit Bans
Article 4 sets out three circumstances under which authorities may stop citizens at the border. Anyone who has served administrative detention for fraudulently obtaining travel documents, or for illegally crossing a border, faces a ban of six months to three years once the penalty ends.
Criminal activity abroad that damages national security or interests carries the same range, with the clock starting upon the citizen’s return to China.
A third ground concerns breaches of export control or technology import and export rules that may endanger industrial or technological security, with commerce authorities deciding, and the text sets no time limit for this category.
Authorities must notify the individual in writing of the facts, reasons, legal basis, and avenues of redress. Article 6, however, permits silence where notice might affect national security or a criminal investigation. That carve-out happens to align with the very categories the new rules expand.
Border officials must also now advise citizens against traveling to destinations Beijing deems high-risk, though a warning alone does not bar exit.
Foreign nationals, meanwhile, face entry bans of one to five years for providing false information in visa or entry applications.
Enforcement Was Surging Long Before the Ink Dried
Data shared with the BBC by rights group Safeguard Defenders show mentions of exit bans in China’s supreme court database rising from 89 in 2016 to 188,760 in 2025.
Over roughly the same stretch, the share of civil verdicts dealing with exit bans grew more than 30-fold, from approximately 0.23% to 7.3%, according to the group.
In March, in a high-profile case, authorities barred Xiao Hong and Ji Yichao, co-founders of the AI startup Manus, from leaving the country while regulators reviewed Meta’s US$2 billion acquisition of their firm, the Financial Times reported.
For years, civil servants and state-owned enterprise employees have surrendered their passports to their employers and sought approval for any trip abroad, according to firsthand accounts given to BBC Chinese.
Beijing rejects the characterization of a country closing its doors. Piyao, the government’s rumor-refuting platform, insists the rules “do not restrict the travel of ordinary citizens” and target only high-risk destinations and unusual travel patterns.
Citizens have no way to check whether a ban applies to them, however; most would discover a restriction only at the airport.
A state formalizing its power to keep citizens home could register in the investment migration market wherever it happens. When that state is China, whose nationals sit at or near the top of applicant tables across most programs, it could read as a memo about one of the market’s centers of gravity.
“They Leave Before They Get the Knock on the Door”
David Lesperance of Lesperance & Associates, who advises ultra-high-net-worth (UHNW) families on tax and citizenship planning, says the new rules confirm a calculation his Chinese clients have already made.
They are taking what he calls a “realpolitik approach”: either comply with tax obligations, restructure through “decanting trusts, insurance,” and similar tools, or get “themselves and as many of their assets as possible permanently out of China.”
In his view, those choosing the exit door are not being paranoid. His clients recognize that “it is extremely difficult to document 15+ year old financial transactions,” and that in China, “tax authorities don’t send letters… they put in exit bans.”
Looming over all of it, Lesperance adds, is “the 99.9% conviction rate if criminally charged with tax evasion.”
“So it is unsurprising to see they are choosing to leave before they get the proverbial ‘knock on the door’,” he concludes. Because these families anticipate that their Chinese passports will be canceled, “they are getting new passports (if they don’t already have one) and residence permits to live in new locations which meet all their families’ needs.”
Hui Li of Athens-based Hellenic Investment Fund doubts the rules add much urgency, noting that many golden visa holders “are living in China sound and well” and treat the permit as a plan B. Clients in his pipeline are proceeding, but that “arises from organic demand,” he argues, “not due to such newly published and executed rules.”
Among his Chinese clients mid-application in Greece, “the mood among them is very relaxed,” and Li expects the bans to apply only “to a very narrow population.”
Even so, he concedes that from the investor’s perspective, “it is always the earlier the better to have cards in hand.”
The Market’s Single Biggest Client Base
Few residency or citizenship by investment programs of consequence lack a Chinese-led applicant table.
In Greece, Chinese nationals held 10,593 initial golden visa investor permits as of February 2026, 48.1% of the total, with Turkish nationals a distant second at 16.3%.
Portugal’s ledger tells the same story over a longer arc. At the last detailed nationality count in 2023, Chinese investors had received 44% of all golden visas issued since the program opened in 2012, a cumulative lead no other nationality approaches.
The pattern holds across the Caribbean. Chinese applicants remain the largest nationality in the history of Antigua & Barbuda's program, at 21.5% of all applications through mid-2024. They also led Grenada's applicant table in 2024 at 23%, though their share there softened to 13% in the first half of 2025.
Saint Lucia stopped disclosing applicant nationalities after FY2022-23, a year in which Chinese applicants again held the top spot. Even so, its FY2024 annual report reveals that China accounted for the largest share of subjects screened by due diligence firm Exiger.
Viewed regionally, the European Commission's seventh visa suspension mechanism report counted 1,099 Chinese applications to the five Caribbean programs in 2023-2024, second only to Iran's 1,918.
In the United States, freedom-of-information data published by the American Immigrant Investor Alliance in January show that mainland Chinese investors filed roughly half of all EB-5 petitions since the program's 2022 reform.
Pre-reform applicants, meanwhile, still wait behind a queue stretching back to 2016.
The Fine Print for the Market
For firms serving Chinese clients, the operational risks are concrete. An applicant under an undisclosed ban may be unable to attend a biometrics appointment, close on a property in person, or satisfy a program's physical presence requirement.
Neither he nor his advisor will necessarily know until he reaches the border.
The regulation's intermediary provisions bite on the China side of the channel: domestic agencies must register with immigration authorities by mid-December, and overseas firms may no longer sell exit-entry services directly inside China.
Outbound agencies now need a documented relationship with an overseas partner. A registered agency also carries a duty to refuse, and report, any public official who seeks foreign nationality or residence rights in breach of the rules that bind him.
Professionals who travel to China to court that market carry their own exposure: the new entry bans of one to five years apply to anyone providing false information in a visa or entry application. Marketing trips continue regardless, as the 400-strong Guangdong gathering suggests, but the margin for sloppy paperwork has narrowed.
Whether the new rules dampen Chinese demand or accelerate it is a question the coming quarters' program data will answer. What has already changed is the legal environment in which that demand forms.
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