Can Someone Else File Your China Visa or Residence Permit? Article 19's Three Circumstances, and Three Registration Systems Not to Confuse

"Give me your passport and I'll take it to the exit-entry office and renew it for you." If someone has said that to you, this article is for you.

There is black-letter law on this: who may hand in a foreigner's paperwork is set out in article 19 of the Regulations on Administration of the Entry and Exit of Foreigners. It is a good deal narrower than "I'll take care of it", and which part is narrow depends on which document you are applying for. Worse, on one particular question the State Council's Regulations and the National Immigration Administration's own service guides do not say the same thing.

This article puts the texts for those questions side by side. There is a checklist at the end, one line per kind of reader.

Not covered here: stay and residence permits issued for diplomatic and official purposes (article 28 of the Regulations sends those elsewhere), permanent residence, and port visas. The Regulations, the Exit and Entry Administration Law and the NIA texts apply nationwide; the work-permit section names the accepting agencies, address and counter arrangements for Guangzhou only — check locally for other cities.

This is not legal advice. Where penalties, detention or exit-entry bans are involved, consult a licensed lawyer. Local counters may apply these texts differently; the accepting authority's requirements at the time govern.

1. Find your row first

This table is the summary of the whole article. The source text behind every row is quoted in the sections that follow.

Work permits and visas/residence permits run through two different windows under two different rule sets. In Guangzhou the first is handled by the Guangzhou Municipal Science and Technology Bureau and the Huangpu and Nansha District Science and Technology Bureaus; the second by the exit-entry administration of the public security organ. Collapsing both into "doing my visa" is the single most common misunderstanding we see.

2. The default is "in person"

Start here, because it is the background to every exception. The lead sentence of article 16, paragraph 1 of the Regulations of the People's Republic of China on Administration of the Entry and Exit of Foreigners, official English (1 sentence):

A foreigner applying for a residence permit shall submit his or her passport or other international travel documents, qualified photos, and material relating to the purpose of application, go through the relevant formalities in person with the exit and entry administration authority of the public security organ of the local people's government at or above the county level in the proposed places of his or her residence, and provide biometric identification information such as fingerprints thereto.

Subparagraphs (1) to (5) follow in the same paragraph, setting out the material required for work, study, journalist, reunion and personal-matters residence permits respectively. They say nothing about who files, so they are not quoted here. Article 16 has one further paragraph, on the health certificate required for a residence permit valid for more than a year; section 6.1 uses it.

The fingerprints are not an invention of the Regulations; they come from the statute above them. The first sentence of article 30, paragraph 2 of the Exit and Entry Administration Law of the People's Republic of China, official English (that paragraph runs to 3 sentences in English and 2 in Chinese; the rest concerns the 15-day examination and is not about who files):

Applicants for foreigners' residence permits shall submit their passports or other international travel documents, as well as relevant information of specific application matters, and provide biometric identification information such as fingerprints.

Article 16 of the Regulations imposes the in-person rule only on a first application for a residence permit. For visa extensions, changes and reissuance, and for stay permits, the Regulations themselves do not carry that sentence — the documents that do are NIA operational texts, and there is more than one: both the Service Guide for Approving Extension, Change and Reissuance of Foreigners' Visas (17 July 2019) and the Notice on Applications by Foreigners for Visas and Certificates (13 May 2020) carry it. See section 4.

3. Article 19 of the Regulations is where the exception lives

The current text of the Regulations was promulgated on 12 July 2013 by State Council Order No. 637 and re-promulgated as amended by State Council Order No. 814 of 7 August 2025. Order No. 814 changed exactly two things, both introducing the K visa (one subparagraph added to article 6 as subparagraph (6), and one added to article 7 paragraph 1 as subparagraph (6)); article 19 was not touched by that amendment.

Article 19 runs to 2 paragraphs, 2 sentences. Here it is in full, in the official English:

In one of the following circumstances, the inviting entity or individual, the relative of the applicant or the specialized service agency concerned may apply for extension, change or reissuance of a visa or residence permit, or apply for a stay permit on behalf of the applicant: (1) The applicant is under the age of 16 or over the age of 60 or it would unduly inconvenience the applicant due to illness or other reasons; (2) The applicant's current entry is not his or her first entry into China and the applicant has a good record of stay or residence in China; or (3) The inviting entity or individual has guaranteed to cover the necessary expenses of the applicant incurred in China.

If the applicant is a person of high talent who is needed, or a specialist who is urgently needed, by the State, or is in the circumstance prescribed by subparagraph (1) of the preceding paragraph, the inviting entity or individual, the relative of the applicant or the specialized service agency concerned may apply for a residence permit on his or her behalf.

Read it as three questions:

Which applications can be filed by someone else? Paragraph 1 covers two groups: extension, change and reissuance — of a visa and of a residence permit, because in that sentence those three acts attach to both nouns — and, separately, applying for a stay permit. Paragraph 2 deals on its own with applying for a residence permit, that is, the first application.

Who may file? Both paragraphs give an identical list of three: the inviting entity or individual, the applicant's relative, and the specialized service agency concerned. Even the order is the same.

What has to be satisfied? Paragraph 1 requires any one of the three circumstances, not all three. Paragraph 2 narrows the gate to two categories: a person of high talent needed by the State or an urgently needed specialist, plus anyone in "the circumstance prescribed by subparagraph (1) of the preceding paragraph" — under 16, over 60, or unduly inconvenienced by illness or other reasons. Subparagraph (2) of paragraph 1 (a non-first entry with a good record) and subparagraph (3) (the inviting party guaranteeing expenses) are not carried into paragraph 2.

There is one thing the Regulations do not do: they never say what "the specialized service agency concerned" is. That phrase appears exactly twice in the whole instrument, both times in these two paragraphs of article 19. There is no definition clause and no qualification threshold. The Chinese word for "filing" or "record-filing" (备案) appears zero times in the entire Regulations. That gap is where the registration systems of section 6 come from.

4. On one question, two service guides are narrower than the Regulations

Below the Regulations, the National Immigration Administration has published several operational documents. On the question of who may file on your behalf, they do not all agree.

Notice on Applications by Foreigners for Visas and Certificates (National Immigration Administration, 13 May 2020), item III "How to apply" — our working translation, 4 sentences:

A foreigner applying for extension, change or reissuance of a visa or residence permit, or for a stay permit, shall go through the relevant formalities in person with the exit and entry administration authority of the public security organ. In any one of the following circumstances, the inviting entity or individual, the applicant's relative or the specialized service agency concerned may file on the applicant's behalf: (1) the applicant is under the age of 16 or over the age of 60, or it would unduly inconvenience the applicant due to illness or other reasons; (2) the applicant's current entry is not his or her first entry into China and the applicant has a good record of stay or residence in China; (3) the inviting entity or individual has guaranteed to cover the necessary expenses of the applicant incurred in China. A foreigner applying for a residence permit shall go through the relevant formalities in person with the exit and entry administration authority of the public security organ. Where the applicant is a person of high talent needed by the State or an urgently needed specialist, or is in the circumstance under subparagraph (1) of the preceding paragraph, the inviting entity or individual, the applicant's relative or the specialized service agency concerned may file on the applicant's behalf.

This one lines up with article 19: extension, change and reissuance of a residence permit sit in the same sentence as visas and get the three circumstances; only the first application for a residence permit is narrowed to two categories. It, like the earlier Service Guide for Approving Extension, Change and Reissuance of Foreigners' Visas (17 July 2019), supplies the half-sentence the Regulations omit — that the visa track is likewise "in person".

Now the Service Guide for Issuing Foreigners' Residence Permits (National Immigration Administration, 5 September 2019), item IV "Conditions of application", third paragraph — our working translation, 1 sentence:

A foreigner applying for a residence permit, or for its extension, change or reissuance, shall go through the relevant formalities in person with the exit and entry administration authority of the public security organ; where the applicant is a person of high talent needed by the State or an urgently needed specialist, or is under the age of 16 or over the age of 60 or unduly inconvenienced by illness or other reasons, the inviting entity or individual, the applicant's relative or the specialized service agency concerned may file on the applicant's behalf.

That is the whole difference. This sentence folds "extension, change or reissuance" in with "applying for a residence permit" and applies the two-category gate to both. Item VII(1) of the same document repeats it with a one-character difference, and the corresponding paragraph of the Service Guide for Issuing, Extending, Changing and Reissuing Foreigners' Residence Permits on the NIA's online service platform is written the same way. The Regulations run the other way: extension, change and reissuance of a residence permit are governed by article 17, which requires only that the applicant "fill out an application form and submit his or her passport or other international travel documents, qualified photos, and material relating to the purpose of application" — there is no "in person" clause there. We counted every occurrence of 本人 ("in person" / "his or her own") in the full Chinese text of the Regulations: 7 in all, and "go through the relevant formalities in person" appears only in article 16. The other six are "his or her own passport" in articles 7, 12, 16 and 17, and "borne by the person himself or herself" and "unable to bear it himself or herself" in article 32.

In practice the difference is this: a foreigner who has lived in China for six years with a good record, coming in only to renew a residence permit, may have the company file for him under article 19 paragraph 1 subparagraph (2) — but under these two residence-permit service guides he has to come himself.

The sharper way to put it is not "conflict" but "one paragraph left out". Item II of both residence-permit service guides gives their basis as the Exit and Entry Administration Law and these Regulations. They do not set up a narrower rule of their own; in restating article 19 they restate paragraph 2 and leave paragraph 1 out. A counter working from the guides is still bound by the Regulations.

What to do about it, in three lines:

1. The Regulations rank higher. They are administrative regulations made by the State Council; a service guide is an operational document published by the NIA.
2. The Notice is the later text. It is dated 13 May 2020; the two residence-permit service guides are dated 5 September 2019 and 13 March 2019.
3. But you are the one in the queue. Which text a given counter follows may vary by city, and we cannot answer for the accepting authority. Phone ahead and ask specifically whether a residence-permit renewal may be filed by the employer — it is cheaper than finding out at the counter. In Guangzhou the public hotline is 020-12345.

5. Even where someone may file, several things still fall on you

"Filing on behalf" covers exactly one act: handing in the paperwork. On either side of it, you are still personally in the frame.

Item zero is the passport itself. Before you hand it over, read article 38, paragraph 1 of the Exit and Entry Administration Law, official English (2 sentences):

Foreigners having reached the age of 16 who stay or reside in China shall carry with them their passports or other international travel documents, or foreigners' stay or residence permits, and accept the inspection of public security organs. Foreigners who reside in China shall, within the prescribed time limit, submit foreigners' residence permits to public security organs under local people's governments at or above the county level in the places of residence for examination.

The subject there is you as well: for the days your passport sits in someone else's drawer, the duty to carry it and submit to inspection does not travel with it (article 76, paragraph 1, subparagraph (1) of the same Law: a warning, and a fine of up to RMB 2,000). Article 18, paragraph 3 of the Regulations does leave a way out — "during the period of time when the applicant's passport or other international travel documents are retained for processing his or her application for a visa or permit, the applicant may stay in China legally on the strength of the receipt of acceptance" — but it says retained by the authority. Your employer or an agency holding it for you is not in that sentence.

First, fingerprints. Article 16 paragraph 1 of the Regulations and article 30 paragraph 2 of the Law both require "biometric identification information such as fingerprints", and the subject is the applicant. Neither the Regulations nor the guides quoted above say what happens to the fingerprints when someone else files, and we will not answer for the accepting authority. What can be said from the text is this much: the fingerprint clause sits in article 16 of the Regulations (applying for a residence permit) and article 30, paragraph 2 of the Law, while article 17 — extension, change and reissuance — does not carry it. That does not mean a counter will not take them; whether and how is for the accepting authority, so it is still the second question to ask on the phone.

Second, the interview. Service Guide for Issuing Foreigners' Residence Permits, item VII(3) "Review" — our working translation, 2 sentences:

The exit and entry administration authority of the public security organ shall verify the truthfulness of the purpose of application by means such as interview, telephone inquiry and on-the-spot investigation, and shall confirm that the applicant holds foreign nationality. Where the applicant or the entity or individual concerned is notified to attend an interview and fails, without proper reason, to attend within the agreed time, the authority may lawfully refuse to issue the visa or certificate.

Note the consequence in the second sentence: missing the interview without proper reason means no certificate is issued. Having someone file for you does not transfer that summons.

Third, collecting the document. Same service guide, item X "Delivery of result" — our working translation, 1 sentence:

An approved foreigner's residence permit must be collected in person by the applicant, on the strength of the receipt of acceptance, at the exit and entry administration authority of the public security organ.

The visa track says the same thing: item X of the Service Guide for Approving Extension, Change and Reissuance of Foreigners' Visas reads "an approved visa for a foreigner must be collected in person by the applicant, on the strength of the receipt of acceptance, at the exit and entry administration authority of the public security organ".

Fourth, the signature. The name on the application form is yours. That is where the instruction in section 9 — check that the signature on the form is actually yours — comes from.

So if anyone promises you "full agency service, you never have to show up", these are the sentences to hold it against.

6. Two "filings" and one "registration" — three systems, three purposes

This is the section readers most often blur together. In the world of foreigners' documents the Chinese term 备案 — record-filing — now refers to two distinct systems, and a third thing sits beside them under the name 注册, registration. Who registers, where, and what it buys are different in each.

6.1 Inviting and receiving entities filing with exit-entry administration

Notice on Applications by Foreigners for Visas and Certificates, item IV "Entity filing" — our working translation, 1 sentence:

An entity that invites or receives foreigners may apply to the local exit and entry administration authority of the public security organ for filing.

Note "may", not "shall". So why bother? See the last sentence of the "work" category under item VI(2) of the Service Guide for Issuing Foreigners' Residence Permits — our working translation, 1 sentence:

For foreign persons of high talent, urgently needed specialists and investors, a residence permit with a residence period of up to 5 years may be issued; for persons working at a filed entity in good standing, a residence permit with a residence period of up to 2 years may be issued; for other persons, a residence permit with a residence period of up to 1 year may be issued.

Same employee: working at a "filed entity in good standing" means a residence period of up to 2 years instead of 1. Over a five-year posting, the difference between an annual trip to the counter and a biennial one is two trips saved. This one is aimed at employers: it is something you can do for your staff that costs nothing.

Two caveats. First, whether the "filed entity" in this sentence is the entity produced by the "entity filing" quoted just above is an inference of ours: neither text names the other. Both are published by the National Immigration Administration and both use the same Chinese term, but the source does not tie them together — take both sentences with you when you ask. Second, the guide does not say how "good standing" is assessed or what a filing requires; both are for the local exit-entry administration authority to specify.

Two things not to misread. The guide says a residence permit "may be issued" with a residence period "of up to 2 years" — that is a discretionary ceiling, not an automatic grant once an entity has filed. And the last paragraph of article 16 of the Regulations reads "when applying for a residence permit valid for more than 1 year, a foreigner shall, in accordance with relevant provisions, submit his or her health certificate. A health certificate is valid for six months beginning from the date of issue" — so the 2-year tier costs a medical the 1-year tier does not. We have written about that separately: the work-permit medical examination and health certificate in Guangzhou.

Entity filing has one more visible payoff: under item VII of the Notice on Applications by Foreigners for Visas and Certificates, holders of F, M and R visas applying for an extension must submit a letter from the inviting or receiving entity, and "an entity that has not filed shall additionally submit its registration certificate" — filing saves the entity that document.

6.2 The work-permit track: specialized service agencies register in the "System"

Guangzhou Foreigner's Work Permit application guide, opening of item VI "Application Procedures", official English (2 sentences):

The handler and the service agency entrusted by the employer handle with Foreigner's Work Permit (hereinafter referred to as the "FWP") in the Service System for Foreigners Working in China. No fee will be charged by the accepting agency.

That second sentence is worth memorising on its own — the official step is free. What an agency charges you is its own service fee, not a government fee.

The same note recurs in the material tables for each type of business in the guide. Official English (3 sentences; the Chinese runs to 2 — the extra break belongs to the English text):

When a specialized service agency is entrusted, the employer's Power of Attorney (collect the original) shall be submitted to clearly state the authorized agency, the authorized person and the authorized scope, as well as the ID number and the contact number of the authorized person. The authorization is made on case-by-case basis and one person shall be authorized with only one case. The specialized service agency should be registered in the System.

That note appears 11 times in the material tables of the guide, spread across business items (2) to (6): once under applying for a Foreigner's Work Permit, once under short-term work in Guangzhou (90 days or less), once under the Confirmation Letter for High-End Foreign Talent, five times across the "extension, change, reissuance, cancellation and cancellation of the notification letter" group, and three times across the "foreign graduates and foreign interns" group; each time followed by the sentence requiring the agency to be registered in the System. "One person authorized with only one case" means one power of attorney covers one authorized person and one matter; you cannot sign a single blanket authorization letting an agency run every case for everyone all year.

Note that this registration is a registration in the science and technology authority's business system, covering the work-permit track only. It is not the same thing as the filing in 6.3.

6.3 From 15 September 2026: filing of exit-entry intermediary services

Provisions of the State Council on Exit and Entry Administration (State Council Order No. 841, executed 22 July 2026, released 31 July 2026, in force from 15 September 2026), article 7 paragraphs 1 and 2 — our working translation, 2 paragraphs, 4 sentences:

The State applies filing administration to institutions and personnel that, on the commission of persons exiting or entering China, engage in intermediary services such as exit-entry policy consultation, handling of documents and handling of formalities.

An institution engaging in exit-entry intermediary services shall file with the immigration administration authority at its locality within 15 days from the date of its establishment. Personnel engaging in exit-entry intermediary services shall have the filing formalities handled by the institution they belong to. Those already engaged in exit-entry intermediary services before these Provisions take effect shall complete filing formalities within 90 days from the date these Provisions take effect.

This lands squarely in the gap article 19 leaves open: the Regulations permit you to entrust "the specialized service agency concerned" without defining it, and from 15 September 2026 Order No. 841 builds a filing system for such institutions. Paragraph 3 of article 7 leaves the detailed measures to be made by the national immigration administration department together with the State Council's market regulation and other competent departments.

As of 14 September 2026 those detailed measures do not exist. On that date we read through the listing pages of both the "Policy Documents" and "Notices and Announcements" sections of the National Immigration Administration's website: the newest entry under Policy Documents is still Order No. 841 itself, dated 31 July 2026, and the newest under Notices and Announcements is the announcement dated 28 August 2026 suspending issuance of electronic border-area permits for Shigatse, Tibet. Neither is the measures. The Expert Interpretation of the Provisions posted on the NIA site says that "the national immigration administration department is working with the relevant departments to formulate the specific measures for filing administration, and, we understand, will mainly use online channels so that intermediary service institutions can complete filing efficiently". So until the measures and a list are published there is no way to check whether a given agency has filed — the list does not exist yet. Do not try, and do not trust a screenshot from anyone claiming "we are already filed". Our clause-by-clause reading of Order No. 841 is here: State Council Order No. 841: intermediary filing, liability for invitation letters, and time limits on exit-entry bans.

The three side by side

7. Hiring someone to file does not move the liability with the paperwork

People assume that once it is handed to an agency, a problem with the material is the agency's problem. That is not what the texts say.

Article 20 of the Regulations, official English (1 sentence):

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 3, paragraph 3 of Order No. 841 — our working translation, 1 sentence:

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

In other words: the entity or individual that issued the letter or the certification is responsible for its truthfulness and has to cooperate with verification. That responsibility does not move because an agency sits in the middle.

The converse also needs saying: the liability not moving does not mean the agency carries none of its own. Article 10 of Order No. 841 forbids an intermediary institution from "publishing false information, or soliciting clients by means such as exaggerated or misleading promotion", and from "providing or assisting in providing false material, or assisting another person to obtain a visa, stay or residence permit, passport or other exit-entry document or formality in breach of the rules". Article 13 provides for an order to correct within a time limit, confiscation of illegal gains and a fine for disturbing exit-entry administration order; where the institution refuses to correct or the circumstances are serious, the competent departments are notified to suspend its business, order it to halt for rectification, or revoke its business licence or business permit, and the persons in charge who are directly responsible and other persons directly responsible are fined RMB 10,000 to 50,000. Article 16 requires the immigration administration authority to keep a reporting channel open and handle reports promptly. So from 15 September 2026, a pitch of the "full agency service, you never have to show up" kind is itself within range of article 10, subparagraph (1).

When something goes wrong, the penalties land in three places.

On whoever issued the invitation letter. Article 74 of the Exit and Entry Administration Law, official English (2 paragraphs, 2 sentences):

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.

Read "shall also be ordered to bear exit expenses of the invited foreigners" twice — on top of the fine there is an airfare. Order No. 841 article 11, paragraph 2 adds another layer — our working translation, 3 sentences:

Where an individual issues a false letter of invitation or other false application material for another person's application for exit, entry, stay or residence, the immigration administration authority shall impose a fine of not less than RMB 5,000 but not more than RMB 10,000; any illegal gains shall be confiscated. Where an entity commits the foregoing act, it shall be fined not less than RMB 10,000 but not more than RMB 50,000; any illegal gains shall be confiscated; and the persons in charge who are directly responsible and other persons directly responsible shall be fined not less than RMB 5,000 but not more than RMB 10,000. Where the law provides otherwise, those provisions apply.

On the application itself. Article 21 of the Regulations, official English (excerpt):

In one of the following circumstances, the exit and entry administration authority of the public security organ shall not approve the application for extension, change or reissuance of a visa or residence permit, or the application for a stay permit, submitted by a foreigner: … (2) The applicant has knowingly falsified information in the application process; …

On the foreigner personally. Article 73 of the Exit and Entry Administration Law, official English (2 paragraphs, 2 sentences):

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.

Note the "where circumstances are serious" tier in paragraph 1: detention for not less than 10 days but not more than 15 days.

And one more layer lands on your status. Order No. 841, article 5, paragraph 2 — our working translation, 2 sentences:

Where a foreigner has been criminally punished for obstructing national (border) administration, or has been administratively punished for obtaining exit-entry documents by fraud or for illegal exit or entry, the immigration administration authority may, in light of the circumstances of the violation and the need to prevent offences, decide that the foreigner shall not be allowed to enter China for 1 to 5 years from the date the punishment has been served. Where the law provides otherwise, those provisions apply.

The fine paid and the detention served, it is not necessarily over: the immigration administration authority may separately decide on a 1-to-5-year entry ban. Beyond that, article 62 of the Law lists illegal residence and illegal employment among the grounds for repatriation, and its last paragraph reads "repatriated persons shall not be allowed to enter China for one to five years, calculated from the date of repatriation"; article 81, paragraph 3 sets 10 years for a foreigner who has been deported; and article 17 of Order No. 841 reads "where a violation of these Provisions constitutes a crime, criminal liability shall be pursued in accordance with law". Which tier anyone falls into is for the accepting authority and the courts, not for us. No legal advice here, just the text on the page: who filled in the form and who bears the consequence are two different questions.

8. The material: foreign-language certification documents must be translated into Chinese

Item XII "Other notes" of the Service Guide for Issuing Foreigners' Residence Permits has 4 numbered points plus a closing line. Point (1) explains who counts as a family member, point (2) lists which documents qualify as proof of family or kinship relations, and point (4) explains what each kind of identity document means. This section quotes point (3) and that closing line — our working translation, 2 sentences:

Marriage certificates, birth certificates, proof of kinship, proof of change of name and similar documents issued by a foreign competent authority or notarial body shall be authenticated by the Chinese embassy or consulate in that country.

The relevant foreign-language certification documents shall be translated into Chinese.

The second sentence is the basis for what we do, and it is plain: foreign-language certification documents need a Chinese translation. The guide does not say who must produce the translation or whether a notary office's seal is required; that is for the accepting authority to specify.

The first sentence needs a date check. This service guide was published on 5 September 2019 and the Notice on Applications by Foreigners for Visas and Certificates on 13 May 2020 — both before 7 November 2023, the date on which, per the Ministry of Foreign Affairs announcement, the Convention Abolishing the Requirement of Legalisation for Foreign Public Documents entered into force for China, so that a public document from a contracting state used on the Chinese mainland needs only that state's apostille and no consular legalisation. Whether your document travels by legalisation or by apostille depends on the rules in force between the issuing country and China at the time, and the accepting authority's position still governs. We have written about that track separately: Apostille, translation and seals for work-permit documents.

If what you are applying for is a reunion or personal-matters residence permit, the documents usually needing translation are the marriage certificate and the birth certificate. Our certificate shop has pages for both: Chinese translation of a foreign marriage certificate and Chinese translation of a foreign birth certificate (the pages are written around household registration as the use case; the translation itself is the same document). Pricing goes by what language the original is in, not by the language you are reading.

9. If you have already hired an agency, or you are heading to the counter

Check the date before you check who goes. Article 32 of the Exit and Entry Administration Law, official English (2 sentences):

Foreigners residing in China who apply for the extension of the duration of residence shall, within 30 days prior to the expiry of the validity period on their residence permits, file applications with the exit/entry administrations of public security organs under local people's governments at or above the county level, and submit relevant information of specific application matters in accordance with relevant requirements. If upon examination, the reasons for extension are appropriate and sufficient, an extension shall be granted; if an extension is denied, the foreigner concerned shall leave China on the expiry of the validity period specified in their residence permits.

On the visa track, article 29 of the same Law requires an application to extend the duration of stay "within seven days prior to the expiry of the duration of stay specified in the visa"; a foreigner whose visa requires a residence permit after entry has "30 days from the date of entry" under article 30, paragraph 1; and a change to a registered item on a residence permit must be filed "within 10 days of the change" under article 33, paragraph 2. The question of who files has to be settled before those dates. Spending a week on the phone about whether the employer may file, and missing the 30-day mark, makes the question moot.

If your residence permit has already expired, or you have already missed the 30-day mark: there is no relief clause for this — none of the texts quoted here says what to do after the fact. Article 25, subparagraph (1) of the Regulations makes staying beyond the permitted period illegal residence, and article 78, paragraph 1 of the Law, official English (1 sentence):

Foreigners who reside in China illegally shall be given a warning; where circumstances are serious, they shall be imposed with a fine of RMB 500 yuan per day, with a cap of RMB 10,000 yuan in total, or be detained for not less than five days but not more than 15 days.

The fine accrues daily, so "today" and "next week" are not the same thing, and illegal residence is also on the article 62 list of grounds for repatriation. For this one, get a licensed lawyer now and let the lawyer decide how and when to approach the exit-entry administration authority.

If you have already handed your material to an agency: the filing list does not exist yet, so there is nothing to check it against. Three things you can do instead: keep a copy of the power of attorney you signed (on the work-permit track it is one authorization per person per case anyway, so ask your employer for a copy of it); confirm that the signature on the application form is actually yours; and confirm which entity issued the invitation letter or certification letter in your file — because the penalties in section 7 land on whoever issued it.

If an invitation letter or certification document has already been submitted and you now find the content is untrue: do not quietly file a corrected version over it. Talk to a licensed lawyer first, then decide who says what, when, and to which authority. Article 20 of the Regulations says the parties "shall cooperate"; how and when to cooperate is not something we can judge for you.

If you are heading to the counter soon: first work out which application you are actually making (check it against the table in section 1), then phone the accepting authority with two questions — may this particular application be filed by the employer or a relative, and if so, does the applicant still have to appear for fingerprints. The number is the Guangzhou Government Service Hotline, 020-12345; ask to be put through to the accepting authority. Bring money: residence-permit fees are set by the Notice of the National Development and Reform Commission and the Ministry of Finance (Fa Gai Jia Ge [2004] No. 2230) at RMB 400 for a permit valid up to 1 year, RMB 800 for 1 year (inclusive) to 3 years, and RMB 1,000 for 3 years (inclusive) to 5 years (inclusive) — item IX of the service guide.

If what you need is a work permit rather than a visa or residence permit: the accepting agencies are the Guangzhou Municipal Science and Technology Bureau and the Huangpu and Nansha District Science and Technology Bureaus, the application is filed online, and the accepting agency charges no fee. One address is easy to get backwards: what moved on 9 October 2025 was the Guangzhou Foreigner's Work Service Window — the work-permit track — which relocated into the Guangzhou Immigration Service Center, the same building as the public security exit-entry hall: One-Stop Service Window for Foreigners Working in China, 4th Floor, Entry and Exit Reception Hall for Foreigners of Guangzhou Public Security Bureau, No. 155 Jiefang South Road, Yuexiu District, open Monday to Friday 9:00–12:00 and 13:00–17:00; the former counters 516 and 517 on the 5th floor of the Guangzhou Government Affairs Center closed after 30 September 2025 (Guangzhou Municipal Science and Technology Bureau, 19 September 2025). It is the work-permit window that moved; confirm separately with the accepting authority where visa and residence-permit business is handled. We have written separately about what happens when you change employers: Changing employers: a work permit is not "amended", it is cancelled and applied for again.

10. One line, pick yours

Every line says who it is addressed to. The subject is the person who can actually perform the act.

1. You are a foreign employee applying for a residence permit for the first time — go in person and give fingerprints. Only two categories may have someone file for them: a person of high talent needed by the State or an urgently needed specialist, and anyone under 16, over 60, or unduly inconvenienced by illness or other reasons (Regulations articles 16 and 19 paragraph 2). But "someone may file" is not "no fingerprints" — neither provision says what happens to the fingerprints when someone else files (section 5), so ask the accepting authority.
2. You are a foreign employee renewing a residence permit with a good record in China — this is the row where the Regulations and the two residence-permit service guides disagree (section 4). Phone the accepting authority first, then decide who goes. Do not simply have the company file it on the strength of article 19 paragraph 1 subparagraph (2). And mind the date: a residence-permit extension must be applied for within 30 days prior to expiry (Law article 32), which is a harder constraint than who files.
3. You are only extending, changing or reissuing a visa, or applying for a stay permit — here article 19 paragraph 1 and the Notice on Applications by Foreigners for Visas and Certificates agree: any one of the three circumstances lets those three kinds of filer act for you — but an approved visa, per the service guide, is likewise collected in person on the receipt of acceptance, and an extension of the duration of stay must be applied for within seven days prior to expiry.
4. You are in HR or administration — the free thing you can do for your staff is find out whether your organisation can complete an "entity filing"; people working at a "filed entity in good standing" can get a residence period of up to 2 years rather than 1. The certification letter you issue for an employee does not carry liability for the entity alone: article 74 paragraph 2 of the Law and article 11 paragraph 2 of Order No. 841 fine the entity (RMB 10,000–50,000) and separately fine "the persons in charge who are directly responsible and other persons directly responsible" (RMB 5,000–10,000) — the person who drafts and signs may well be in that tier. Article 74 is triggered by issuing "in violation of this Law", not by issuing a letter at all; but whether the content is true has to be checked before you sign, not after it is filed.
5. You are an employer entrusting an agency with a work permit (Guangzhou) — one power of attorney per person per case, and the agency must be registered in the "System"; the official acceptance is free of charge. What you pay is the agency's own service fee.
6. You are the Chinese spouse or another relative of a foreign employee — "the applicant's relative" is already on the list of three in article 19, but whether you may file still depends on which application it is and which paragraph it falls under.
7. You hold a residence permit for study — your school is usually the receiving entity, and filing follows the lines above. But article 22 of the Regulations applies to you alone: off-campus work-study or an internship requires your school's approval first, then an application to the exit-entry administration authority to have the place and duration of the work-study or internship endorsed on your residence permit; without that endorsement you may not take off-campus work-study or an internship. "The school handles everything" does not mean the endorsement was obtained.
8. You are an accompanying spouse or child — on the personal-matters track (entry on an S1 visa to visit family), the Service Guide for Issuing Foreigners' Residence Permits says a residence permit may be issued "for a residence period matching that of the person being visited"; on the reunion track (entry on a Q1 visa) it says up to 3 years for those under 18 and over 60, and up to 2 years for everyone else. Renewing the employee's permit does not renew the family's — those dates run separately.
9. You are an institution providing exit-entry intermediary services — filing administration applies from 15 September 2026, and the two tracks are different: a newly established institution files with the immigration administration authority at its locality within 15 days of establishment; an institution already in business before that date files within 90 days of the effective date. But as of today the detailed measures are unpublished, so there is no channel and nobody can actually file. Two things you can do meanwhile: watch the announcements of the immigration administration authority at your locality; and bring yourself in line with article 8 (lawfully established; the legal representative or person in charge free of criminal punishment for an intentional crime; staff with the relevant professional knowledge plus funds and premises appropriate to the services; sound management systems — and note that overseas enterprises and institutions may not provide exit-entry intermediary services inside China). The consequence of not filing is in article 12: an order to correct within a time limit; on refusal, a fine of RMB 5,000–10,000 plus notification to suspend the business or halt for rectification; in serious cases, a fine of RMB 10,000–50,000 plus notification to revoke the business permit or business licence. Until the measures are out, do not tell clients "we are already filed".
10. You have been notified to attend an interview — failing to attend without proper reason means the certificate is not issued. This applies whether someone filed for you or you filed yourself.
11. Your foreign-language certification documents have no Chinese translation yet — get the translation done before you go; the guide says they "shall be translated into Chinese". Who produces it and whether notarisation is needed is for the accepting authority to say.
12. You have found untrue content in your material — get a licensed lawyer, do not patch it yourself. The penalties are in section 7: beyond the fine and the 10-to-15-day detention tier, the immigration administration authority may separately decide on a 1-to-5-year entry ban (Order No. 841, article 5 paragraph 2), and a violation amounting to a crime draws criminal liability (article 17).

11. Sources and versions

• Regulations of the People's Republic of China on Administration of the Entry and Exit of Foreigners: promulgated by State Council Order No. 637 on 12 July 2013, amended and re-promulgated by State Council Order No. 814 of 7 August 2025 with the numbering of provisions adjusted accordingly — in practice only the subparagraph numbers inside articles 6 and 7 shifted; the article numbers did not. Chinese text at the central government portal (that page gives 7 August 2025 as the date of execution and 14 August 2025 as the date of release; Order No. 814 took effect on 1 October 2025). The official English used above is the version posted by the National Immigration Administration, which is the 2013 Order No. 637 text; since Order No. 814 touched only article 6 and article 7 paragraph 1, articles 16, 19, 20, 21 and 36 are unaffected.
• Exit and Entry Administration Law of the People's Republic of China: Chinese text at the National Immigration Administration; official English at en.nia.gov.cn.
• Provisions of the State Council on Exit and Entry Administration (State Council Order No. 841): Chinese text at the central government portal; the officials' press Q&A is at the National Immigration Administration, and the Expert Interpretation sits in the same section (the sentence about the filing measures quoted in section 6.3 comes from the Expert Interpretation, not from the press Q&A). We have not found an official English text of Order No. 841. As of today the Laws and Regulations section of the NIA's English site still lists only the instruments uploaded in 2021, and the item the central government's English portal published on 31 July 2026 is a news release of roughly 200 words with no article numbers. A full English rendering is posted at chinajob.com, dated 2 August 2026, but that page states it is for reference only and that the Chinese version prevails — it is not an official translation; note also that it renders Order No. 841 as "Regulations", whereas in this article "Regulations" always means the 条例. Every passage from Order No. 841 above is our own working translation, and the Chinese text governs.
• Notice on Applications by Foreigners for Visas and Certificates: National Immigration Administration, 13 May 2020, Chinese original. Chinese only; the English above is ours.
• Service Guide for Issuing Foreigners' Residence Permits: National Immigration Administration, 5 September 2019, Chinese original. The Service Guide for Issuing, Extending, Changing and Reissuing Foreigners' Residence Permits on the online service platform is here (that page carries no date of its own; 13 March 2019 is inferred from its URL path). Chinese only; the English above is ours.
• Service Guide for Approving Extension, Change and Reissuance of Foreigners' Visas: National Immigration Administration, 17 July 2019, Chinese original — this one matches article 19 paragraph 1.
• Guangzhou Foreigner's Work Permit application guide (2020 revision) and its official English version: Guangzhou Municipal Science and Technology Bureau.
• The Convention Abolishing the Requirement of Legalisation for Foreign Public Documents entered into force for China on 7 November 2023: Ministry of Foreign Affairs.
• The residence-permit fees (RMB 400 / 800 / 1,000) come from the Notice of the National Development and Reform Commission and the Ministry of Finance on Fee Standards for Foreigners' Residence Permits and Related Matters (Fa Gai Jia Ge [2004] No. 2230), as reproduced in item IX of the service guide above.

A detail about time limits: article 18 of the Regulations gives the receipt of acceptance for a residence-permit application a validity "not exceeding 15 days", which looks shorter than the "15 working days" in the service guide. There is no conflict — the last paragraph of article 36 of the Regulations, official English (1 sentence):

The period of time for examination and approval or the validity period of the receipt of acceptance of the exit and entry administration authority of the public security organ in these Regulations is calculated in terms of working days, excluding legal holidays.

Two Chinese-English mismatches worth flagging: item VI of the Guangzhou work-permit guide says in Chinese that the permit is handled by the employer's own handler or by a handler designated by an agency the employer has entrusted, while the official English reads "The handler and the service agency entrusted by the employer" — Chinese has "or", English has "and", and the Chinese text governs. The Chinese version also gives the system address as http://fwp.safea.gov.cn/ while the English version gives https://fuwu.most.gov.cn/lhgzweb/. Read both against a later announcement: the Announcement on Migration of the Service System for Foreigners Working in China and the Foreign Expert Project Management Information System, sourced to the Ministry of Science and Technology and posted on the Guangzhou Science and Technology Bureau's site on 3 June 2024, states that the systems have moved to the Ministry of Human Resources and Social Security's National Human Resources and Social Security Government Service Platform (www.12333.gov.cn), that the Ministry of Science and Technology's service platform (fuwu.most.gov.cn) no longer provides related technical support, and gives the declaration-end address as https://fwp.safea.gov.cn/lhgzweb/. The guide is the 2020 revision; on this point the 2024 announcement governs. In one line: use https://fwp.safea.gov.cn/lhgzweb/ for filing, and stop using fuwu.most.gov.cn; for the login entry point, follow whatever the Ministry of Human Resources and Social Security platform publishes at the time.

Every passage quoted above has been checked word by word against the sources listed. Local counters may apply these texts differently; the accepting authority's requirements at the time govern.