China’s State Council has ordered every company offering emigration, visa, and exit-entry services to formally register with national immigration authorities. Premier Li Qiang signed Order No. 841 on July 22, 2026, ending an unregulated market period that began in 2018.
The new regulation officially takes effect on September 15, 2026. It establishes strict filing procedures for intermediaries serving China, which is one of the world’s largest source markets for global investment migration.
Who Must File and Key Deadlines
Under Article 7 of the regulation, all agencies and individual staff providing client consultation, document processing, and intermediary services for exit-entry procedures must complete formal filings:
- Existing Agencies: Companies already operating before September 15 have a 90-day grace period, making mid-December 2026 the final filing deadline.
- New Agencies: Newly established agencies must file with local immigration authorities within 15 days of setting up their business.
- Exemptions: Free consultation or public advice offered without a profit motive does not require registration.
The National Immigration Administration (NIA) clarified that the system is not a return to pre-approval permits, but rather an online registration system paired with post-entry conduct supervision.
Requirements for Agencies and Ban on Foreign Firms
To register successfully, agencies must meet specific operational standards outlined in Article 8. The agency legal representatives and frontline staff must carry no criminal record for intentional crimes. Agencies must also demonstrate adequate operational funds, physical office space, and data security systems.
Crucially, agencies handling outbound emigration must hold a valid, signed cooperation agreement or letter of intent with a recognized overseas service partner.
Furthermore, overseas companies and institutions are explicitly banned from selling exit-entry intermediary services inside China directly. However, foreign-invested companies lawfully established within mainland China are still allowed to operate.
Strict Conduct Rules and Penalties
Article 10 prohibits agencies from publishing false information, making misleading promises, or assisting clients with fraudulent application documents.
Additionally, if public officials or military personnel attempt to acquire foreign citizenship or overseas residence permits in breach of state regulations, agencies must refuse service and report the attempt to government supervisors.
Failing to register or operating without meeting the required conditions will result in correction orders and fines ranging from RMB 5,000 to RMB 50,000 (approx. US740toUS7,400). In serious cases, authorities will suspend business operations or revoke business licenses.
What Overseas Partners Should Do
While foreign investment migration firms and developers located abroad do not face direct filing duties in China, their local Chinese agency partners do.
International project developers and immigration law firms should immediately ensure they have signed formal, written representation agreements with their Chinese agency partners to help them meet the mid-December 2026 deadline.
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