China's State Council Order No. 841, in force 15 September 2026: agent filing, invitation-letter liability, fixed periods for exit and entry bans

On 15 September 2026 the Regulations of the State Council on Exit and Entry Administration (State Council Order No. 841) take effect. There are only 19 articles, but three of the things in them land directly on ordinary people and ordinary companies: agencies that handle exit-entry formalities for others have to file with the authorities; the entity or individual who signs an invitation letter for a foreigner is liable for the truthfulness of its content and of the matters it certifies; and a foreigner who submits false materials can be barred from entering China for 1 to 5 years.

This piece sets out the articles that concern you, quotes the source text, and says for each one who it binds, from what date the clock runs, how much the fine is, and which questions still have no answer today.

The sources are Order No. 841 (adopted at the 90th executive meeting of the State Council on 29 June 2026, signed by the Premier on 22 July 2026, released on the Chinese government portal on 31 July 2026, effective 15 September 2026), the Exit and Entry Administration Law of the People's Republic of China, the Regulations of the People's Republic of China on Administration of the Entry and Exit of Foreigners (below, the Foreigners Entry-Exit Regulations), and the press Q&A and expert commentary published on the National Immigration Administration website. There is no official English version of Order No. 841 (evidence in section 10): passages from Order No. 841, the press Q&A and the expert commentary quoted below are our own working translation, and the Chinese text governs. Quotations from the Exit and Entry Administration Law are the official English published by the Chinese Consular Service Network; quotations from the Foreigners Entry-Exit Regulations are the official English on the National Immigration Administration's English site (uploaded in 2021 — the two articles quoted here were not touched by the 2025 amendment). Local practice varies — the accepting authority's own answer governs.

1. Which of the 19 articles applies to you

Who you are	Articles that bind you	In one line
Agencies and staff handling exit-entry formalities or documents for others under a commission	Articles 7, 8, 9, 10, 12, 13, 17	You must file; there are conditions; there are six prohibitions. The worst case is not a fine: under Article 13 the fine can be 1 to 5 times the illegal gains (no RMB 50,000 ceiling), directly responsible persons are fined a further RMB 10,000–50,000, and business permits or the business licence can be revoked; criminal liability follows under Article 17
A Chinese entity or individual signing an invitation letter for a foreigner	Article 3(3), Article 11(2)	Liable for the truthfulness of the invitation content and the certified matters; fines if false
A foreigner applying for a visa, stay or residence	Articles 3 and 5, Article 11(1)	Your stated reason must be true; false materials when applying for a visa outside China or entry at a port can mean 1 to 5 years barred from entry
Anyone who has already filed materials and now fears something in them is wrong (especially applicants inside China for an extension or replacement)	Article 11(1)	It routes document fraud wholesale to the Exit and Entry Administration Law and the Passport Law; the Law's Article 73 tier carries 10 to 15 days' detention
A Chinese citizen barred from leaving China	Articles 4 and 6	Two of the three grounds carry 6 months to 3 years, the third states no period; the deciding authority must notify you in writing of the remedies
A Chinese citizen about to travel, work or study abroad	Article 2	The safety-alert and destination-risk-warning system (not covered here)

Article 2 deals with preventing security risks for Chinese citizens travelling abroad. It is not on the same chain as the three threads of this piece, so it is flagged here and left there.

2. This time it is filing, not administrative licensing — but it does not replace the licences your industry already needs

Start with the thing most likely to be misread. Filing is not approval, and it is not a revival of the old operating licence. The history is set out plainly in the expert commentary on the National Immigration Administration website, by Qi Lixin, president of the Beijing Migration and Exit-Entry Service Industry Association (北京市移民及出境入境服务行业协会):

To strengthen administration and regulation, in 2001 the state began to apply licensing administration to private exit-entry intermediary service agencies, requiring such agencies to apply for an operating licence. After the operating licence for private exit-entry intermediary service agencies was abolished in 2018, the number of intermediary service agencies grew rapidly and intermediary service activity became increasingly active.

2 sentences in all. The same piece gives the order of magnitude:

According to incomplete statistics, as of June 2026 there were more than 160,000 agencies whose business scope includes "private exit-entry intermediary services", many of them established after the private exit-entry intermediary service licence was abolished in 2018.

1 sentence in all. Note what the 160,000 counts: agencies whose business scope includes the activity, not agencies actually carrying it on — and the sentence itself says "according to incomplete statistics".

The same piece is explicit about the regulatory choice:

It should be pointed out in particular that the Regulations do not use the previous approach of supervision by prior administrative licensing and approval, but establish a filing administration system and strengthen process supervision… the aim being that agencies and individuals engaged in exit-entry intermediary service activities carry on business in accordance with law and regulation, through professional and honest service.

This is an excerpt; the ellipsis stands for four parallel clauses of evaluative commentary. So the rule is not "from 15 September you may not operate without a filing" but "if you carry on this service you must file, and if you do not, Article 12 applies". Those two are very far apart in consequence, and section 7 puts the penalty text on the table.

But do not read "not a licence" as "no licence of any kind". Article 12(1) says itself that in serious cases the relevant competent department shall be notified to "revoke the relevant business permit or the business licence" — the phrase "relevant business permit" tells you this industry already has its own qualifications behind it (foreign labour cooperation, overseas employment agency work, study-abroad services and so on each have their own regulator and requirements; this piece does not go into them). The filing under Order No. 841 is a layer on top of those; it does not replace them.

3. Article 3: your stated reason must be true, and you must cooperate

This is the widest-reaching article in the whole instrument — Chinese citizens and foreigners are both inside it. The source text has 4 paragraphs, 1 sentence each:

The reason for which a person entering or leaving China applies for exit, entry, stay or residence shall be true and lawful.

When verifying the identity and the stated reason of a person entering or leaving China, immigration authorities and visa authorities may ask about the relevant circumstances and require the person to produce or provide relevant documents, materials, electronic data and other information, and the person entering or leaving China shall cooperate.

Where an entity or an individual issues an invitation letter or other application materials for a person entering or leaving China, it shall be responsible for the truthfulness of the invitation content and the matters certified, and shall cooperate with immigration authorities and visa authorities in verifying the relevant information.

Where a person entering or leaving China provides false materials or makes a false statement, immigration authorities and visa authorities have the right to decide not to issue an exit-entry document or not to allow that person to exit or enter China.

Three places are worth stopping at.

First, the second paragraph lists "relevant documents, materials, electronic data and other information". Electronic data is written in by name, and it is followed by an open-ended "and other" — the list is not closed. The duty that faces it is Article 9(2), 1 sentence in all:

Relevant competent departments and their staff shall keep confidential, in accordance with law, the state secrets, work secrets, trade secrets, personal privacy and personal information they learn in the course of performing their duties.

What you hand over under Article 3(2) sits inside that confidentiality duty.

Second, the third paragraph puts "issues an invitation letter" and "other application materials" side by side, and the duty falls on "an entity or an individual" — a letter signed by a private person counts too.

Third, what the third paragraph makes you responsible for is the truthfulness of "the invitation content and the matters certified", plus a separate duty to cooperate in verification. That is wider than the Exit and Entry Administration Law's original wording; the next section puts them side by side.

One more thing belongs here. Article 3(4) gives the consequence as "not to issue an exit-entry document or not to allow that person to exit or enter China" — that is not the whole consequence. Article 11(1) routes document fraud out of these Regulations entirely, 1 sentence in all:

Where a person fraudulently obtains a visa, a stay or residence permit, a passport or another exit-entry document by means such as providing false materials or making a false statement, the immigration authority shall impose a penalty in accordance with the Exit and Entry Administration Law of the People's Republic of China and the Passport Law of the People's Republic of China.

At the Exit and Entry Administration Law end, that lands on Article 73, whose official English has 2 paragraphs, 1 sentence each:

Article 73 Persons who obtain exit/entry documents such as visas or stay or residence permits by resorting to fraudulent acts shall be fined not less than RMB 2,000 yuan but not more than RMB 5,000 yuan; where circumstances are serious, they shall be detained for not less than 10 days but not more than 15 days and shall also be fined not less than RMB 5,000 yuan but not more than RMB 20,000 yuan.

Entities engaging in any of the acts prescribed in the preceding paragraph shall be fined not less than RMB 10,000 yuan but not more than RMB 50,000 yuan; and the persons in charge of the entities who are directly responsible and other persons directly responsible shall be punished in accordance with the provisions in the preceding paragraph.

The thing to see in that article is not the money — it is "detained for not less than 10 days but not more than 15 days". Article 11(1) also routes to the Passport Law; we have not checked the penalties at that end, so we do not set them out here.

4. What the person who signs an invitation letter is liable for: old and new

"Whoever issues the invitation letter is liable for its truthfulness" did not arrive in 2026. It has been in Article 19 of the Exit and Entry Administration Law since 2013. The official English, 2 sentences in all:

Article 19 Where foreigners applying for visas need to provide written invitations issued by entities or individuals within China, the applicants shall provide such invitations in accordance with the requirements of the visa-issuing authorities abroad. Entities or individuals that issue written invitations shall be liable for the fidelity of the contents.

The duty to "cooperate in verification" is not a 2026 invention either. Article 20 of the Foreigners Entry-Exit Regulations (promulgated in 2013 as State Council Order No. 637, re-promulgated after amendment by State Council Order No. 814 in 2025) sits in Chapter III, "Administration of Stay and Residence". Its official English is 1 sentence in all:

The exit and entry administration authority of the public security organ may verify the purpose of application through such means as interview, telephone inquiry and on-the-spot investigation, and the applicant as well as the entity or individual that has provided the letter of invitation or certification documents shall cooperate.

Article 20 carries no limiting words of its own. The chapter it sits in governs foreigners' visa and stay-or-residence-permit business inside China — first applications for a residence permit as well as extension, replacement, reissue and stay permits are all in that chapter. The body to cooperate with is written as the exit and entry administration authority of the public security organ, and it already names the entity or individual that provided the certification documents. (One divergence to flag: the Chinese reads 核实申请事由的真实性, "verify the truthfulness of the stated reason"; the official English renders it as "verify the purpose of application" and drops the truthfulness. The official English is narrower here; the Chinese governs.)

A duty to cooperate with visa authorities was also already there. Same Regulations, last paragraph of Article 8, official English, 1 sentence in all:

Where the visa authority abroad requires relevant departments or entities in China to help with the verification of relevant information, the latter shall cooperate.

Note who is bound there: "relevant departments or entities in China" — no individuals. Put the two together and what Article 3(3) of Order No. 841 actually widens is three things: the person bound goes from "entities" to "an entity or an individual"; the setting goes from the Regulations' two specific moments (a visa authority abroad verifying before issue, and a public security exit-entry authority verifying a domestic application) to all applications for exit, entry, stay or residence; and it names cooperation with "immigration authorities and visa authorities" in one breath.

The penalty is not new either. Article 74 of the Law, 2 paragraphs, 1 sentence each:

Article 74 Persons who issue written invitations or other application materials to foreigners in violation of this Law shall be fined not less than RMB 5,000 yuan but not more than RMB 10,000 yuan, with the illegal gains confiscated if there are any, and shall also be ordered to bear exit expenses of the invited foreigners.

Entities engaging in any of the acts prescribed in the preceding paragraph shall be fined not less than RMB 10,000 yuan but not more than RMB 50,000 yuan, with the illegal gains confiscated if there are any, and shall also be ordered to bear exit expenses of the invited foreigners; the persons in charge of the entities who are directly responsible and other persons directly responsible shall be punished in accordance with the provisions in the preceding paragraph.

One difference in wording is worth noting: the trigger in Article 74 of the Law is issuing invitations or other application materials to foreigners "in violation of this Law" — the word "false" is not in it; Article 11(2) of Order No. 841 says "false invitation letter or other false application materials" in terms.

Article 11(2) of Order No. 841, 3 sentences in all:

Where an individual issues a false invitation letter or other false application materials for another person applying for exit, entry, stay or residence, the immigration authority shall impose a fine of not less than RMB 5,000 and not more than RMB 10,000, and any illegal gains shall be confiscated. Where an entity commits the aforesaid act, it shall be fined not less than RMB 10,000 and not more than RMB 50,000, any illegal gains shall be confiscated, and the directly responsible person in charge and other directly responsible persons shall be fined not less than RMB 5,000 and not more than RMB 10,000. Where laws provide otherwise, those provisions shall apply.

Put the three side by side:

	Exit and Entry Administration Law (2013) and the Foreigners Entry-Exit Regulations (as amended 2025)	Order No. 841 (in force 15 Sep 2026)
Scope of the truthfulness duty	The invitation content (Law, Article 19, visa invitations only)	The invitation content and the matters certified; the materials widen from "an invitation letter" to "an invitation letter or other application materials" (Article 3(3))
Duty to cooperate in verification	Already there in two places: Regulations, Article 8, last paragraph (visa authority abroad verifying; bound party limited to "relevant departments or entities in China") and Article 20 (public security exit-entry authority verifying a domestic application; bound party includes whoever provided the invitation letter or certification documents)	The bound party widens to "an entity or an individual", the setting widens to all applications for exit, entry, stay or residence, and cooperation with immigration authorities and visa authorities is named (Article 3(3))
Whom the letter is for	Issued to foreigners (Law, Article 74)	Issued for another person applying for exit, entry, stay or residence, not limited to foreigners (Article 11(2))
Fine on an individual	RMB 5,000 to 10,000	RMB 5,000 to 10,000
Fine on an entity	RMB 10,000 to 50,000	RMB 10,000 to 50,000
Directly responsible persons	Punished on the individual scale	RMB 5,000 to 10,000
Extra consequence	Ordered to bear the invited foreigner's exit expenses	Not written into the text
On conflict	——	"Where laws provide otherwise, those provisions shall apply" (last sentence of Article 11(2))

In other words: the money did not change, and the duty to cooperate in verification was not invented here either. Three things did change — the truthfulness duty widened from "the invitation content" to "the invitation content and the matters certified", and the materials widened from "an invitation letter" to "an invitation letter or other application materials"; the party bound to cooperate widened from "entities" to "an entity or an individual" and the setting from two specific moments to every application; and the false-materials penalty widened from "issued to foreigners" to "issued for another person applying for exit, entry, stay or residence". The order to bear the invited foreigner's exit expenses appears only in Article 74 of the Law and is not in Order No. 841; the last sentence of Article 11(2) is "where laws provide otherwise, those provisions shall apply", and how the two fit together is for the immigration authority to apply.

For the company sending invitation letters to overseas buyers around the Canton Fair, the employer issuing supporting documents for a foreign employee, the private person inviting a foreign friend, this section reduces to one line: you have to be able to account for how the document you signed came about, and you have to cooperate when it is checked.

5. What counts as an "exit-entry intermediary" — and the one exclusion that is clear today

The definition in Article 7(1) is 1 sentence in all:

The state applies filing administration to agencies and personnel that, under a commission from persons entering or leaving China, engage in intermediary services such as exit-entry policy consultation, handling documents on their behalf and handling formalities.

Note "such as policy consultation, handling documents on their behalf and handling formalities" — an open-ended list, not a closed set of three.

The press Q&A gives one exclusion, 1 sentence in all:

Policy consultation, enquiry and similar activities that are not carried on for profit do not fall within the exit-entry intermediary services referred to in these Regulations.

That sentence is limited to activities "not carried on for profit" — it is about the purpose of the activity, not the legal form of whoever provides it. Read the other way, consultation carried on for profit is, on the face of it, inside Article 7(1).

The press Q&A also addresses foreign investment, 1 sentence in all:

Foreign-invested and Hong Kong-, Macao- and Taiwan-invested enterprises and organisations lawfully established within China may engage in exit-entry intermediary services in accordance with law.

That does not conflict with Article 8(3), "overseas enterprises and organisations shall not provide exit-entry intermediary services within China": the dividing line is whether the entity is lawfully established inside China, not where the capital comes from.

How wide is the industry? The same expert commentary names names, 1 sentence in all:

At the same time, agencies engaged in exit-entry intermediary services are complex and varied and their numbers are not clearly known: there are the emigration agents and study-abroad agents that used to simply provide citizens with settlement-abroad and study-abroad services, there are the foreign labour-cooperation agents and overseas-employment agents that organise citizens to work abroad or provide employment services, and there are also law firms and travel agencies that have taken up exit-entry intermediary service activities.

Study-abroad agents, labour agents, overseas-employment agents, law firms and travel agencies are all in there. The boundary today rests on the article text and these few lines of commentary; the filing measures have not been published (see section 10) — so "does my line of work count" cannot be answered from public documents today.

6. Two deadlines: 15 days and 90 days

Article 7 has 3 paragraphs, 5 sentences, and the three sentences of the second paragraph are the whole of the filing-route and timing rule:

The state applies filing administration to agencies and personnel that, under a commission from persons entering or leaving China, engage in intermediary services such as exit-entry policy consultation, handling documents on their behalf and handling formalities.

An agency engaged in exit-entry intermediary services shall file with the immigration authority of the place where it is located within 15 days from the date of its establishment. Personnel engaged in exit-entry intermediary services shall have the filing formalities handled by the agency to which they belong. Those already engaged in exit-entry intermediary services before these Regulations take effect shall complete the filing formalities within 90 days from the date these Regulations take effect.

The specific measures for filing administration of agencies and personnel engaged in exit-entry intermediary services shall be formulated by the national immigration administration department together with the market regulation and other competent departments under the State Council.

Those three sentences govern three different things: newly established agencies file within 15 days of establishment; staff do not go themselves, the agency files for them; and those already doing this before 15 September file within 90 days of the effective date. The text says 15 days, not 15 working days — count calendar days.

There is also something the text does not answer. The first paragraph says filing administration applies to "agencies and personnel", but the second gives only two routes: the agency files for itself, and personnel are filed by the agency they belong to. Across Articles 1 to 19 the word "filing" appears only in Article 7 and in the phrase "beyond the filed scope" in Article 10(1)(4) — there is no third route, so for a person who belongs to no agency and handles formalities for others in a personal capacity, the Regulations do not say where or how to file. Article 12(2), meanwhile, says an individual carrying on these services in breach of the Regulations shall be ordered to stop. How those two fit together is not written in the Regulations, and again waits on the filing measures. Until they are out, do not conclude for yourself either that individuals may never do this or that individuals need not file.

The text does not give the 90-day end date. Counting from the effective date of 15 September: if 15 September itself is day 1, day 90 falls on 13 December 2026; on the civil-law counting rule that the starting day is not counted and the clock runs from the next day, it falls on 14 December 2026 — but that is a rule of civil law, and Order No. 841 does not say whether an administrative filing deadline is counted that way. Incidentally, 13 December 2026 is a Sunday. The text gives a number of days, not a date — the filing measures published by the immigration authority govern.

"File with the immigration authority of the place where it is located" — the reach of that term comes from Article 18, 2 paragraphs, 1 sentence each:

For the purposes of these Regulations, immigration authorities means the national immigration administration department, exit-entry border inspection authorities, and the exit/entry administrations of public security organs under local people's governments at or above the county level.

For the purposes of these Regulations, visa authorities means visa-issuing authorities stationed abroad and port visa authorities.

Order No. 841 stops at "file with the immigration authority of the place where it is located": which form, which papers, through which system — not a word, all of it left to the filing measures authorised by Article 7(3). The expert commentary indicates the direction, 1 sentence in all:

The national immigration administration department is working with the relevant departments to formulate the specific measures for filing administration and, as we understand it, filing will mainly be done online and by similar means, so that intermediary service agencies can complete the formalities efficiently.

That was written on 31 July 2026, in the present continuous, and the phrase "as we understand it" shows that even its author was reporting at second hand. Do not treat "mainly online" as a channel that already exists.

Article 8(1) lists five conditions a filing agency must meet:

Item	Condition
(1)	Lawfully established
(2)	The legal representative or person in charge has not received criminal punishment for an intentional crime
(3)	Has staff with professional knowledge of exit-entry laws, regulations, policies and the like, and funds and premises commensurate with the intermediary services carried on
(4)	Staff who directly provide intermediary services to persons entering or leaving China have not received criminal punishment for an intentional crime endangering national security or public safety, or impairing border administration
(5)	Has sound management systems, covering personnel management, education and training, record retention, data security, compliance management and the like

Item (2) governs the legal representative or person in charge, and the bar is criminal punishment for an intentional crime of any kind; item (4) governs staff who deal with clients directly, and the offences are confined to intentional crimes in three families — endangering national security, endangering public safety, and impairing border administration. The two items differ in who they cover and how wide they reach; do not merge them.

Article 8 has two further paragraphs, 2 paragraphs, 1 sentence each:

Those engaged in outbound intermediary services shall additionally have established a cooperative relationship with a relevant overseas service organisation or signed a valid letter of intent to cooperate.

Overseas enterprises and organisations shall not provide exit-entry intermediary services within China.

The first of those says "engaged in outbound intermediary services", while everywhere else the text says "exit-entry intermediary services". Whether that is a deliberate distinction or loose drafting, the text does not say. Do not treat "I work the inbound direction, so I need no overseas partner" as settled — if the measures take the opposite reading, an agency that prepared on that basis will be a condition short.

7. Six prohibitions and the penalties

Article 10(1) lists six prohibited acts:

Item	Shall not
(1)	Publish false information, or solicit clients by exaggerated or misleading promotion or similar means
(2)	Provide or assist in providing false materials, or assist others in irregularly obtaining visas, stay or residence permits, passports or other exit-entry documents or formalities
(3)	Disclose, sell or unlawfully provide trade secrets, personal privacy or personal information learned in the course of intermediary service activities
(4)	Carry on exit-entry intermediary services beyond the filed scope
(5)	Organise or assist others in cross-border unlawful or criminal activity
(6)	Other acts endangering national security or interests, or disrupting the order of exit-entry administration

Article 10(2) singles out one class of client, 1 sentence in all:

Where public officials, military personnel or others commission an agency engaged in exit-entry intermediary services to irregularly handle foreign nationality, overseas permanent residence status, overseas residence documents or other exit-entry documents or formalities, the agency engaged in exit-entry intermediary services shall not handle it and shall promptly report to the supervisory organ and other relevant authorities.

That paragraph puts a double duty on the agency: do not handle it, and report it — and the reporting target is written as "the supervisory organ and other relevant authorities".

The penalties split in two. Breaches of Articles 7 and 8 (failing to file, failing to meet the conditions) go to Article 12; breaches of Article 10 (the six prohibitions) go to Article 13. Article 12 has 2 paragraphs, 1 sentence each:

Where an agency engaged in exit-entry intermediary services breaches Articles 7 and 8 of these Regulations, the immigration authority shall order correction within a time limit; where it refuses to correct, a fine of not less than RMB 5,000 and not more than RMB 10,000 shall be imposed and the relevant competent department shall be notified to order suspension of the relevant business or closure for rectification; where the circumstances are serious, a fine of not less than RMB 10,000 and not more than RMB 50,000 shall be imposed and the relevant competent department shall be notified to revoke the relevant business permit or the business licence.

Where an individual carries on exit-entry intermediary services in breach of these Regulations, the immigration authority shall order the unlawful conduct to stop; any illegal gains shall be confiscated; where the circumstances are serious, a fine of not more than RMB 5,000 may also be imposed.

The order of the first paragraph is worth noticing: step one is "order correction within a time limit", and the fine comes after "where it refuses to correct". But whether the "circumstances are serious" tier also requires a refusal to correct first, the text does not make clear — do not treat that order as a reason to wait until someone comes asking. The expert commentary on the National Immigration Administration website puts the consequence of not filing more bluntly than the article does:

…the Regulations provide, for acts by exit-entry intermediary service agencies such as carrying on intermediary services without filing and issuing false materials or fraudulently obtaining exit-entry documents, penalties including an order to rectify within a time limit, confiscation of illegal gains, fines and revocation of the business licence…

That is an excerpt; the ellipses at either end stand for the purpose clause and the evaluative clause of that paragraph.

Article 13, 1 paragraph, 2 sentences, governs the six prohibitions:

Where an agency engaged in exit-entry intermediary services breaches Article 10 of these Regulations and disrupts the order of exit-entry administration, the immigration authority shall order correction within a time limit; any illegal gains shall be confiscated; where the illegal gains are RMB 20,000 or more, a fine of not less than one and not more than five times the illegal gains shall also be imposed; where there are no illegal gains or the illegal gains are less than RMB 20,000, a fine of not less than RMB 20,000 and not more than RMB 50,000 shall also be imposed; where it refuses to correct or the circumstances are serious, the relevant competent department shall be notified to order suspension of the relevant business, closure for rectification, revocation of the relevant business permit or revocation of the business licence; and the directly responsible person in charge and other directly responsible persons shall be fined not less than RMB 10,000 and not more than RMB 50,000. Where laws provide otherwise, those provisions shall apply.

There is a qualifier here that is easy to skim past: the text reads "breaches Article 10 of these Regulations and disrupts the order of exit-entry administration" — the second half is a condition of the article, not decoration.

What was breached	Penalty article	First step	Fine
Articles 7 and 8 (filing, conditions)	Article 12(1)	Order correction within a time limit	Refusal to correct RMB 5,000–10,000; serious cases RMB 10,000–50,000
An individual carrying on intermediary services unlawfully	Article 12(2)	Order the conduct to stop	Serious cases may add up to RMB 5,000
Article 10 (six prohibitions) plus disruption of administrative order	Article 13	Order correction within a time limit	Illegal gains of RMB 20,000 or more: 1–5 times; otherwise RMB 20,000–50,000; directly responsible persons a further RMB 10,000–50,000

That table is administrative penalties only. Article 17 is 1 sentence in all:

Where a violation of these Regulations constitutes a crime, criminal liability shall be pursued in accordance with law.

What items (2) and (5) of Article 10(1) — providing or assisting with false materials and helping others irregularly obtain documents, and organising or assisting cross-border unlawful or criminal activity — amount to under the Criminal Law, and what sentences attach, we have not checked and do not set out here. If either of those is in play, see a practising lawyer before you ask anyone in the trade.

There is one further procedural rule, Article 14: where the exit/entry administration of a public security organ under a local people's government at or above the county level imposes, under these Regulations, a fine exceeding RMB 5,000 or a confiscation of illegal gains, the decision is made by the public security organ to which it belongs.

8. No-exit and no-entry: this time with several explicit periods, though not in every paragraph

Article 4 governs Chinese citizens, 3 paragraphs, 1 sentence each:

Where a Chinese citizen has received administrative detention as a punishment for fraudulently obtaining an exit-entry document or for unlawful exit from or entry into China, the immigration authority may, in the light of the circumstances of the violation and the need to prevent unlawful and criminal conduct, decide that the person shall not be allowed to exit China for a period of 6 months to 3 years from the date the punishment is completed.

Where a Chinese citizen engages abroad in unlawful or criminal activity that endangers national security and interests, the competent department under the State Council, or — after verification by a diplomatic mission abroad or similar body — the provincial people's government of the person's domicile within China, may decide that the person shall not be allowed to exit China for a period of 6 months to 3 years from the date of return to China.

Where a Chinese citizen breaches export control, technology import and export administration or similar rules in a way that may endanger national industrial security or technological security, the commerce and other relevant competent departments under the State Council may decide that the person shall not be allowed to exit China.

The three paragraphs do not start the clock in the same place: the first runs from the date the punishment is completed, the second from the date of return to China, and the third gives neither a period nor a starting point.

Look closely at the trigger in the first paragraph as well: it requires that the person has already "received administrative detention as a punishment". That detention is not created by these Regulations — it comes from the Exit and Entry Administration Law, Article 71 (using forged, altered or fraudulently obtained exit-entry documents and similar acts; 5 to 10 days' detention where circumstances are serious) and Article 73 (fraudulently obtaining documents; 10 to 15 days' detention where circumstances are serious). Without reaching that "serious" tier you do not reach the 6 months to 3 years here.

There is also a number that looks identical and governs something else. Article 75 of the Law, whose official English runs to 1 paragraph, 2 sentences (the Chinese is a single sentence; the split belongs to the official English):

Article 75 Where Chinese citizens are repatriated due to illegally going to other countries or regions after exiting China, exit/entry border inspection authorities shall confiscate their exit/entry documents. Exit/entry document issuing authorities shall refuse to issue new exit/entry documents to such citizens for a period ranging from six months to three years calculating from the date of their repatriation.

Its "six months to three years" governs refusal to issue exit-entry documents; the "6 months to 3 years" in Article 4 of Order No. 841 governs a bar on leaving China. Two different things and two different authorities — do not merge them. (Article 12(1)(4) of the Law adds another: a person subject to criminal punishment for impairing border administration, or repatriated by another country or region for illegal exit, illegal residence or illegal employment, is not allowed to exit China until the No-Exit-from-China period has expired.)

How does this fit the Exit and Entry Administration Law? The expert commentary on the National Immigration Administration website (by Cheng Xiezhong, professor at the China University of Political Science and Law) is explicit, 2 sentences in all:

For example, Article 12 of the current Exit and Entry Administration Law sets out six circumstances in which Chinese citizens are not allowed to exit China, the sixth of which is "other circumstances in which exit from China is not allowed in accordance with laws or administrative regulations". Article 4 of these Regulations adds the circumstance of having received administrative detention as a punishment for fraudulently obtaining an exit-entry document or for unlawful exit from or entry into China, thereby connecting with that provision.

Article 5 governs foreigners, 3 paragraphs, 4 sentences (2 sentences in the second paragraph, 1 in each of the others):

Where a foreigner provides false materials or makes a false statement when applying for a Chinese visa outside China or applying for entry at a port, the immigration authority or the visa authority may decide that the person shall not be allowed to enter China for a period of 1 to 5 years.

Where a foreigner has received criminal punishment for impairing border administration, or administrative punishment for fraudulently obtaining an exit-entry document or for unlawful exit from or entry into China, the immigration authority may, in the light of the circumstances of the violation and the need to prevent unlawful and criminal conduct, decide that the person shall not be allowed to enter China for a period of 1 to 5 years from the date the punishment is completed. Where laws provide otherwise, those provisions shall apply.

Where a foreigner is placed on a countermeasure list, an unreliable entity list or a malicious entity list, or is subject to countermeasures and restrictive measures or similar, and measures such as refusing to issue an exit-entry document or refusing entry need to be taken in accordance with law, the immigration authority and the visa authority shall implement them according to their respective functions.

The first paragraph is tightly bounded as to where: "when applying for a Chinese visa outside China or applying for entry at a port". The closing sentence of the second paragraph, "where laws provide otherwise, those provisions shall apply", is a switch pointing elsewhere — the Exit and Entry Administration Law itself carries several different periods:

Circumstance	Basis	Period
False materials or a false statement when applying for a visa outside China or entry at a port	Order No. 841, Article 5(1)	1 to 5 years barred from entry
Criminal punishment for impairing border administration, or administrative punishment for document fraud or unlawful exit/entry	Order No. 841, Article 5(2)	1 to 5 years from completion of the punishment (unless laws provide otherwise)
Repatriated	Exit and Entry Administration Law, Article 62(3)	Not allowed to enter China for one to five years from the date of repatriation
Deported	Exit and Entry Administration Law, Article 81(3)	Not allowed to enter China within 10 years from the date of deportation

This table only puts the periods side by side. It is not a tool for working out which one applies to you. Which one lands on a particular person depends on the type of punishment and on which authority imposed it — take that to a practising lawyer rather than reading it off a table.

9. What you are entitled to know when you are barred from leaving — and why there is no matching right when you are barred from entering

Article 6 has 2 paragraphs, 1 sentence each:

For a person lawfully decided not to be allowed to exit China, the deciding authority shall promptly notify the immigration authority to carry out the decision in accordance with the rules, and shall notify the person in writing of the facts, reasons, basis and remedies for the no-exit decision; where national security, the investigation of a criminal case or similar may be affected, the person need not be notified.

When carrying out a no-exit decision, the immigration authority shall inform the person in accordance with the content of the notification from the deciding authority.

Read the two halves of the first paragraph separately: before the semicolon is written notice of the facts, the reasons, the basis and the remedies — all four are written in; after the semicolon is the exception, "where national security, the investigation of a criminal case or similar may be affected, the person need not be notified", and that "or similar" is again an open-ended list.

The second paragraph is about enforcement: when you are stopped at a port, what the immigration authority tells you is limited to the content of the deciding authority's notification. It is not the body that can explain the reasons to you. For the reasons and for the remedies, the body to approach is the one that made the decision.

That notification duty is written for "no exit" only. On the entry side — refusal of a visa, refusal of entry — the Exit and Entry Administration Law says the opposite. The last paragraph of Article 21, 1 sentence in all:

The visa-issuing authorities are not required to give reasons for refusing the issuance of a visa.

And the last paragraph of Article 25, likewise 1 sentence in all:

Exit/entry border inspection authorities are not required to give reasons for denying an entry.

The two duties are asymmetric: Article 6 of Order No. 841 is written for no-exit decisions and says nothing at all about no-entry ones. When the entry bans in the previous section land on you, the law does not require anyone to explain why.

So what is left that you can push on yourself? Three things. First, Article 65 of the Law, 1 sentence in all:

Article 65 Where persons are not allowed to exit or enter China upon decisions made in accordance with the law, the decision-making authorities shall duly inform the exit/entry border inspection authorities of such decisions in accordance with relevant regulations; where the circumstances in which the persons are not allowed to exit or enter China disappear, the decision-making authorities shall duly cancel the aforesaid decisions and inform exit/entry border inspection authorities of the cancellation.

In other words, once the circumstances disappear the decision is to be cancelled — you do not have to sit out the period — but the body to ask is the one that made the decision, not the port.

Second, the first paragraph of Article 64 of the Law, 1 sentence in all:

Article 64 Foreigners dissatisfied with the measure imposed on them in accordance with this Law, such as continued interrogation, detention for investigation, movement restriction or repatriation, may apply for administrative reconsideration in accordance with the law, and the administrative reconsideration decision shall be final.

Note what is in that list: repatriation is, deportation is not — deportation under Article 81(2) is decided by the Ministry of Public Security and that penalty decision is final. The two rows sitting side by side in the previous section do not have the same route out. Administrative reconsideration runs to a statutory deadline; we have not checked how many days it is, so ask a practising lawyer the same day.

Third, Article 16 of Order No. 841, 1 paragraph, 2 sentences:

Immigration authorities shall keep channels for reporting violations of exit-entry administration open and shall handle such reports promptly in accordance with law. Reports that do not fall within their own responsibilities shall be promptly transferred to the relevant authorities for handling in accordance with law.

10. Two things that as of 13 September 2026 still do not exist

First, the specific filing measures. Article 7(3) delegates them to the national immigration administration department together with the market regulation and other competent departments under the State Council. As of the date of writing we could not find them on the listing pages of either the "Policy Documents" or the "Notices and Announcements" column of the National Immigration Administration website. Which means: there is no public filing portal yet, no form, and no list of filed agencies to check against. And today is 13 September — Order No. 841 does not take effect until 15 September, so the filing regime has not started: if someone tells you today that they are "already filed", that cannot be true, and the claim itself is the kind of thing Article 10(1)(1) describes, publishing false information or soliciting clients by exaggerated or misleading promotion. Whether it becomes checkable after the effective date depends on how the duty in Article 9(1) to "publish relevant illegal records and negative records in accordance with the law" is implemented.

Second, an official English text. The Laws and Regulations column of the National Immigration Administration's English site still lists the items uploaded in 2021 — the Exit and Entry Administration Law, the Nationality Law, the Foreigners Entry-Exit Regulations and a few others — and not Order No. 841; the Policy Interpretation column does not have it either. The Chinese government's English portal ran a Xinhua news item on 31 July 2026, "China unveils regulation on exit, entry administration", of about 200 words with no article numbers — that is news coverage, not a translation of the text. The only full English we could find is a version published on chinajob.com on 2 August 2026, on a page that itself states: "The English version is for reference only. If there are differences between the English version and the Chinese version, the Chinese version shall prevail." It is not an official translation, and the Order No. 841 passages in this English version are our own working translation, likewise subject to the Chinese text.

Both of these will change. Once the measures authorised by Article 7(3) are issued, the first item here lapses; if the National Immigration Administration's English site uploads an official translation, so does the second. Read this piece together with its date.

11. One line each: what to do now

You are an agency that was already handling exit-entry formalities or documents for others before 15 September: the deadline is filing with the immigration authority of your place within 90 days of the effective date (Article 7(2), third sentence). The filing measures are not out; until they are, what you can do is bring staff, funds, premises and management systems up to the five items of Article 8(1), and check against Article 8(2) whether your business is on the outbound side (if it is, you also need an overseas cooperative relationship or a valid letter of intent). Where will the measures appear? Watch two places: the "Policy Documents" and "Notices and Announcements" columns of the National Immigration Administration website, and announcements from the exit/entry administration of the public security organ where you are, at or above the county level — that is what Article 18 defines.
You are an agency of this kind established after 15 September: your deadline is 15 days from the date of establishment, not 90 days (Article 7(2), first sentence).
The 90 days run out and the measures are still not published: the text has no answer for this — Order No. 841 grants no relief for "wanted to file, had nowhere to file". What you can do is keep evidence: your records of enquiring within the period, and dated proof that you were assembling what Article 8(1) requires. Step one under Article 12(1) is an order to correct within a time limit, not an immediate fine — but whether the "circumstances are serious" tier requires a refusal to correct first, the text does not make clear. The immigration authority's reading at the time governs.
Your employees do this work: the filing formalities are handled by the agency, and staff do not go themselves (Article 7(2), second sentence). Do not read that as "nothing touches the employee": Article 8(1)(4) is a condition on the employee personally (no criminal punishment for an intentional crime endangering national security or public safety, or impairing border administration); and if the agency they belong to never files, whether the words of Article 12(2) — "an individual carrying on exit-entry intermediary services in breach of these Regulations" — reach the employee is not addressed in the text.
You do this in a personal capacity (a one-person studio, taking visa work through your contacts, invoicing through somebody else's company): neither of the two routes in Article 7(2) fits you — you are not an "agency", and there is no agency to file for you. The provision to read is not that 90-day deadline but Article 12(2): an individual carrying on these services in breach of the Regulations is ordered to stop, any illegal gains are confiscated, and in serious cases a fine of up to RMB 5,000 may be added. There is no settled answer here before the measures appear; the two available paths are to establish a legal entity and file as an agency, or to join an agency that will. Because this can mean stopping work, see a practising lawyer.
You are an overseas enterprise or organisation: Article 8(3) says you "shall not provide" these services within China. The press Q&A's position is that foreign-invested and Hong Kong-, Macao- and Taiwan-invested enterprises and organisations lawfully established within China may do so — the line is whether the entity is lawfully established inside China, and that is also the route open to you: establish an entity in China, then file as an agency. Since the conclusion may require you to change your legal vehicle or stop soliciting and charging inside China, see a practising lawyer rather than acting on this piece.
You are a public official or a member of the armed forces: Article 10(2) writes you in by name — where you commission an agency to irregularly handle foreign nationality, overseas permanent residence status, overseas residence documents or other exit-entry documents or formalities, the agency shall not handle it and shall promptly report to the supervisory organ and other relevant authorities. From 15 September, in other words, the act of asking an agency can itself be reported. This is not a question for an agency; take it to your employer's personnel or discipline-inspection channel.
You are a Chinese entity or individual about to issue an invitation letter: before you sign it, check the invitation content and the certified matters until you can account for how they came about, and be ready to cooperate in verification (Article 3(3)) — that duty is continuing, so you need to be able to produce the underlying file when asked. Keep the invitation letter and the material behind it on record. Issuing invitations or other application materials to foreigners "in violation of this Law" is penalised by Article 74 of the Exit and Entry Administration Law (RMB 5,000–10,000 for an individual, RMB 10,000–50,000 for an entity, plus an order to bear the invited foreigner's exit expenses); Article 11(2) of Order No. 841 extends the same amounts to materials "issued for another person applying for exit, entry, stay or residence", and closes with "where laws provide otherwise, those provisions shall apply". If you have already issued one and now see a problem in it, do not quietly issue a corrected version — see a practising lawyer first, then decide who explains what, when, and to which authority.
You are a foreigner applying for a Chinese visa outside China, or for entry at a port: your stated reason must be true (Article 3(1)), and you must cooperate when asked to produce documents, materials or electronic data (Article 3(2)). Supplying false materials in those two settings does not end with that one refusal — Article 5(1) is 1 to 5 years barred from entry.
You are a foreigner applying inside China for an extension or a replacement residence permit: Article 5(1) does not reach you on its face — it is written for "applying for a Chinese visa outside China or applying for entry at a port". What reaches you is Article 11(1), which routes document fraud to the Exit and Entry Administration Law and so to its Article 73: a fine of RMB 2,000 to 5,000, and where circumstances are serious, 10 to 15 days' detention plus a fine of RMB 5,000 to 20,000. Detention is on the table, so see a practising lawyer.
You are a foreigner who has already been punished for document fraud or unlawful exit or entry: Article 5(2) is 1 to 5 years from completion of the punishment, but its last sentence says "where laws provide otherwise, those provisions shall apply", and in the Exit and Entry Administration Law repatriation carries one to five years and deportation carries 10. (If you are a Chinese citizen this box is not yours — yours is the 6 months to 3 years in Article 4(1).) Only a practising lawyer working from your actual penalty decision can settle this box; the table above cannot stand in for that. And remember Article 65: once the circumstances behind a no-exit or no-entry decision disappear, the deciding authority is to cancel it — that is something you can raise.
You are a Chinese citizen who has been told you may not leave: first get the written notice — Article 6(1) requires the deciding authority to notify you in writing of the facts, reasons, basis and remedies. Then follow the remedies it names, and get a practising lawyer early. Asking the enforcing body at the port will not produce the reasons — Article 6(2) limits what it tells you to "the content of the notification from the deciding authority". When the circumstances do disappear, ask the authority that made the decision to cancel under Article 65 rather than waiting the period out.
You want to hire an agency to do it for you: you cannot screen on "are they filed" today — before 15 September the regime has not started, so nobody saying "already filed" can be telling the truth; whether it becomes checkable afterwards depends on how Article 9(1)'s duty to publish illegal and negative records is implemented. What you can use today is the six items of Article 10: if the other side promises a "guaranteed pass" or a "guaranteed visa", or offers to "find a way" to complete your materials, that is exactly what items (1) and (2) of Article 10(1) describe. Put the promises in the contract and keep a record of what you pay. Where there is a real violation, Article 16 requires immigration authorities to keep reporting channels open.

12. Sources and dates

Regulations of the State Council on Exit and Entry Administration (State Council Order No. 841), adopted at the 90th executive meeting of the State Council on 29 June 2026; the decree is dated 22 July 2026 (the Chinese government portal gives 22 July 2026 as the date of the instrument and 31 July 2026 as the release date); effective 15 September 2026. Full text: the Chinese government portal. We compared that text against the copy published by the Embassy of the People's Republic of China in the State of Kuwait; Articles 1 to 19 are identical character for character.
Press Q&A by officials of the Ministry of Justice, the Ministry of Public Security and the National Immigration Administration on the Regulations of the State Council on Exit and Entry Administration, 31 July 2026, National Immigration Administration website.
Expert commentary on the Regulations of the State Council on Exit and Entry Administration, 31 July 2026, National Immigration Administration website. We quote commentary one (Cheng Xiezhong) and commentary three (Qi Lixin).
Exit and Entry Administration Law of the People's Republic of China, in force 1 July 2013. Chinese-English text: Chinese Consular Service Network.
Regulations of the People's Republic of China on Administration of the Entry and Exit of Foreigners, promulgated in 2013 as State Council Order No. 637 and re-promulgated after amendment by the Decision of the State Council to Amend the Regulations (State Council Order No. 814 of 2025), the amendment taking effect on 1 October 2025. Articles 8 and 20, quoted here, were not touched by that amendment, which only added a K-visa item to Article 6 and to Article 7(1). Text and amending decision: the Chinese government portal.
Unofficial English reference translation of Order No. 841: chinajob.com, 2 August 2026, a page that states it is for reference only and that the Chinese version prevails.

This piece was written on 13 September 2026, before Order No. 841 took effect. Procedural details are governed by what the accepting authority publishes at the time; for questions about personal penalties and exit or entry restrictions, consult a practising lawyer — this is not legal advice.