China Releases New Exit-Entry Administration Regulations
On July 31, 2026, China's State Council released new Regulations on the Administration of Entry and Exit that will standardize and enhance China’s oversight of entry and exit across multiple areas of regulatory concern.
U.S. institutions should act now to identify all relevant travel to and from China by institutional stakeholders, evaluate any associated risks, and take steps to mitigate risks.
On July 31, 2026, China's State Council released new Regulations on the Administration of Entry and Exit (“Regulations”), which will come into effect on September 15, 2026. Building upon the Chinese Exit-Entry Administration Law and other existing laws, the Regulations standardize and enhance China’s current framework for the administration of entry into and exit from China. In addition to this administrative aim, the Regulations also aim (1) to safeguard the lawful rights and interests of individuals entering and leaving China and (2) to protect China’s national sovereignty, security, and development interests.
Because the Regulations address a wide range of compliance obligations and potential enforcement priorities, U.S. institutions of higher education should act now to identify and address potential areas of risk.
Enhanced Oversight of Foreign Citizens Entering China
When foreign citizens enter China, they must do so on a visa that correctly represents the purpose of their visit. Individuals whose reasons for traveling to China include business activities, for example, may not enter the country on a visa intended for tourist or family visits. Foreign citizens who have entered China may change the purpose of their visit and apply to the authorities for a visa replacement in accordance applicable regulations. The new Regulations expressly provide that (1) the reasons given when applying for entry must be true and lawful and (2) authorities may require individuals to provide relevant documents, materials, electronic data and other information to verify their identities and grounds for their visit. The Regulations also provide that those who submit false materials or make false statements when applying for a Chinese visa abroad or when applying for entry permit at a port of entry, may be prohibited from entering China for a period of 1 to 5 years. Those who have already received criminal or administrative penalties related to exit-entry violations may be prohibited from entering China for a period of 1 to 5 years starting from the date the penalty is fully served.
Moreover, when applying for certain types of visas (e.g. Visitor/F and Business/M visas), visitors are required to have an invitation letter supporting the reason for their visit. The new Regulations provide that entities and individuals who issue such invitation letters will be responsible for the authenticity of the invitation and must cooperate with authorities in verifying relevant information.
Additionally, the new Regulations expressly address China’s use of sanctions and anti-sanctions measures. Those who are included on the Countermeasures List, the Unreliable Entities List or the Malicious Entities List may be refused entry-exit documents or denied entry.
New “Exit-Entry Intermediary Service” Registration System
A core feature of China’s regulatory oversight across a wide range of industries is that providers of “intermediary services” in regulated industries must include this activity within their registered scope of business activities, which promotes market integrity and helps to protect consumers from deceptive practices, though additional licensing or filing obligations may apply in certain industries. The new Regulations extend this strategy to immigration service providers by establishing a new filing system for agencies and individuals providing “exit-entry intermediary services” such as policy consultation, document processing, and formalities management.
All agencies providing exit-entry intermediary services in China must now file with immigration authorities. Newly established intermediary service agencies must complete the filing process within 15 days of their establishment. Existing intermediary service agencies must complete the filing process within 90 days of the Regulations coming into effect.
Provisions Affecting Exit by Chinese Citizens
The new Regulations provides that Chinese citizens may be detained or otherwise prohibited from leaving China under any of the following circumstances:
They have violated regulations on export controls, technology import and export management, or other relevant provisions that may endanger national industrial or technological security;
They have engaged in illegal or criminal activities abroad that endanger national security or interests; or
They have been subject to administrative detention for fraudulently obtaining exit-entry documents or for illegal exit or entry.
The Regulations establish a process for Chinese authorities to issue official safety alerts for overseas destinations and to advise or even block citizens from travelling to high-risk areas. The Regulations stipulate that authorities must promptly issue public safety alerts for overseas travel and risk warnings for tourist destinations based on the security situations in relevant countries and regions, including war or armed conflict, public order issues, natural disasters, accidents, infectious disease outbreaks, etc. Then, when accepting and processing exit-entry document applications and conducting exit border inspections, immigration authorities must remind Chinese citizens to exercise caution when travelling to high-risk countries or regions. Those who truly need to travel there must be reminded to pay attention to the local security situation and strengthen safety precautions. Authorities may even actively dissuade citizens from travelling to countries or regions where the risk level is highest or where incidents that endanger personal safety frequently and suddenly occur.
Implications for U.S. Higher Education Institutions
Because the new Regulations address issues across so many areas related to travel to and from China, IHEs should act now to identify relevant travel by institution stakeholders and evaluate and mitigate associated risks across multiple fronts.
When university employees or other representatives travel to China for reasons that include matters related to university business, the IHE should verify that they will be traveling on an appropriate visa supported by an appropriate invitation letter (if required) from a Chinese entity or individual.
For U.S. institutions that work with local Chinese agents for exit-entry intermediary services, such as exit-entry policy consultation, visa application assistance, or other intermediary services, the institution should request proof or otherwise verify that the recruiters or agents have completed the filing with immigration authorities as required by the Regulations.
IHEs should closely monitor China’s use of countermeasures, unreliable entity, or malicious entities lists for any potential connections that might trigger scrutiny of their community members who might travel to China.
U.S. higher education institutions should regularly monitor relevant official safety warnings and prepare contingency plans should warning signal potential disruptions to normal travel patterns.
