Information as of 16 September 2026
The filing measures for entry-exit intermediary services, issued by China’s National Immigration Administration and State Administration for Market Regulation, took effect on 15 September 2026. For people working in these services, the initial filing is only the beginning. Changes to personnel, overseas cooperation and contact details must also be reported, and client service records must be kept.
Whether your business needs to file depends on what it actually does. The measures cover services provided in China under a client’s instruction for an agreed fee: advice on entry-exit policies, document applications and related procedures for tourism, business, study, work or settlement. Providing paid policy advice without handling visa applications does not automatically put a business outside the filing requirements.
Once you have checked whether the rules apply, start with the deadline, then work through the documents. If your business has overseas partners, clarify who accepts the client’s instructions, collects fees and provides each service. This guide follows that order.
Who needs to be filed, and where?
The requirements cover the institution itself, its legal representative or person in charge, management staff and employees who directly provide intermediary services. The institution handles personnel filings on their behalf.
Filings go to the exit-entry administration of the public security authority at county level or above where the institution is located. Branches operating in different areas must file separately with their local authorities. The test is the actual business activity, not whether the company calls itself a consultancy, education adviser or immigration service.
When is the filing due? Three different situations
Check when the business was established and when it began providing the relevant services.
| Business situation | Filing deadline |
|---|---|
| Already providing the relevant services before 15 September 2026 | Within 90 days from 15 September 2026 |
| Newly established business providing the relevant services | Within 15 days of establishment |
| Existing business that later starts providing the relevant services | Within 15 days of starting those services |
After submission, the authority issues a filing certificate within five working days if the materials are complete and meet the requirements. If you receive a request to correct or supplement the materials, you must do so within 15 days of being notified. Missing that deadline without a valid reason is treated as abandoning that filing.
Keep the distinction clear when planning: filing and correction deadlines are expressed in days; the authority’s deadline for issuing the certificate is in working days.
Which documents do you need?
The filing materials fall into six groups. Overseas cooperation documents apply to businesses providing outbound intermediary services.
| Item | Required documents |
|---|---|
| Institution details | Institution filing information form |
| Personnel details | Personnel filing information form, proof of identity and proof of employment relationship |
| Criminal record declaration | Declaration of no relevant criminal record for the legal representative or person in charge, and staff directly providing services |
| Business premises | Proof of ownership or lease for the main business premises |
| Internal management systems | A description or self-assessment report covering personnel management, training, recordkeeping, data security and compliance management |
| Overseas cooperation | Cooperation agreement or valid letter of intent, together with an explanation of the cooperation arrangements |
Two details are easy to miss. The criminal record requirement is a declaration, which should be completed against the official form. For overseas cooperation, either an agreement or a valid letter of intent may be used, but an explanation of the arrangements is required in both cases.
What should you clarify with overseas partners?
Domestic institutions providing outbound intermediary services must establish a cooperative relationship with an overseas service institution or sign a valid letter of intent.
There is also a restriction on the overseas partner: overseas companies and institutions may not provide entry-exit intermediary services within China. Preparing cooperation documents is therefore only part of the work. Both parties need to clarify how they will deliver the services.
Set out the following responsibilities, then ask the competent authority or a legal professional to assess whether the arrangement complies with the rules:
- Who deals directly with clients and provides advice?
- Which company does the client engage, and who collects the fees?
- Which services does each party provide inside and outside China?
- Does the actual working arrangement match the cooperation documents?
The two source documents do not spell out how every form of remote advice, online lead generation, referral or commission arrangement should be treated. Being based overseas, providing a service online or having a signed cooperation agreement is not enough, on its own, to establish that an arrangement complies.
Which changes must be reported after filing?
Changes to the following information must be filed within 15 days of the change.
| Type of change | Information to track |
|---|---|
| Institution and business | Name, main business premises and business scope |
| Personnel | Personnel already on file |
| Cooperation | Cooperation arrangements with overseas institutions |
| Contact details and online accounts | Contact person, telephone number, email address, website and other media accounts |
Where the change-filing materials are complete and meet the requirements, the authority issues a replacement certificate within five working days. Assigning one person to collect changes can help prevent a missed filing when personnel, business operations and social accounts are managed by different colleagues.
Client service records must also be maintained. For each service, record the recipient, the services provided and the outcome, and properly retain contracts, personal information, financial vouchers and related documents. These can be organised alongside existing client files.
What conduct is prohibited?
The rules identify six categories of prohibited conduct covering advertising, document handling, information protection and other aspects of service delivery:
- Publishing false information or attracting clients through exaggerated or misleading advertising.
- Providing or helping to provide false materials, or assisting with the unlawful handling of visas, stay or residence documents, passports or related documents and procedures.
- Disclosing, selling or unlawfully providing commercial secrets, personal privacy or personal information obtained while providing services.
- Providing relevant intermediary services beyond the scope recorded in the filing.
- Organising or assisting cross-border criminal or other unlawful activities.
- Other conduct that harms national security or interests, or disrupts the administration of exit and entry.
A separate requirement applies to certain client instructions. If public officials, military personnel or other covered persons ask a business to unlawfully obtain foreign nationality, overseas permanent residence status, residence documents or other entry-exit documents or procedures, the business must refuse and promptly report the matter to supervisory authorities or other relevant bodies. The condition that the request involves unlawful handling is essential.
Three common questions
Do we need to file if we only provide paid advice, without handling visas?
Paid advice on entry-exit policies is within the scope. The assessment depends on the actual client engagement, fees and services provided.
Can domestic institutions still work with overseas institutions?
The rules require domestic outbound intermediaries to have overseas cooperation arrangements, while restricting overseas institutions from providing services within China. The specific division of responsibilities still needs to be checked.
Are there ongoing requirements after filing?
Yes. Changes must still be reported, and client service records must be maintained.
What else would you like Zagdim to explain about the new filing rules? Let us know.
This article provides general information. Individual business arrangements need to be assessed on their own facts.
References
National Immigration Administration and State Administration for Market Regulation, “Measures for the Filing Administration of Institutions and Personnel Providing Exit-Entry Intermediary Services” (Chinese) / Guangzhou Public Security Bureau, republication of the “State Council Provisions on Exit and Entry Administration” (Chinese)
