The new regulations on entry and exit management by the Chinese Communist Party (CCP) are set to take effect soon. The Shanghai Private Entry and Exit Service Industry Association convened a meeting with its member units to convey the new regulations. Insiders in Shanghai’s industry revealed that this was a preparatory meeting aimed at conveying and implementing the regulations to immigration intermediary agencies. The publicized articles only specify the registration of intermediary agencies and their employees, without detailing how client data should be submitted and shared. Sources familiar with the matter disclosed that in practice, client data needs to be reported to relevant departments.
The “Notice No. 23 of Shanghai Entry and Exit Association (2026)” issued by the Shanghai Private Entry and Exit Service Industry Association indicated that the meeting was held at 2 p.m. on September 3rd at the Third Floor Multipurpose Hall of the Guesthouse of Shanghai International Studies University, located at 189 West Ti Yu Hui Road, Hongkou District, Shanghai.
According to the notice, in response to the regulations on entry and exit management issued by the State Council of the CCP, the association organized a “special exchange and seminar activity,” requiring participants to prepare relevant questions in advance and engage in interactive discussions on-site.
Ms. Guo, an insider in Shanghai’s industry, disclosed to Dajiyuan that this meeting was not a regular seminar but rather a session to convey policies and explain articles to immigration intermediary companies, requiring related organizations to prepare for implementation after September 15th. She mentioned, “The publicly available part is vague, only stating that intermediary companies need to operate in a standardized manner, and that both the companies and employees need to be registered, without specifying the details. In the future, they may require the preservation or submission of client data and application details to have an understanding of the applicants.”
The regulations outlined in the officially implemented “Regulations on Entry and Exit Management by the State Council” on September 15th consist of a total of 19 articles. Article 7 stipulates that institutions and personnel engaged in intermediary services such as policy consultation, document processing, and procedures for outbound and inbound personnel at the request of such individuals must undergo registration management. Intermediary institutions need to register with the local immigration management institution, while employees should be registered by their respective organizations. Institutions and personnel already engaged in related businesses before the implementation date must complete registration within 90 days of implementation.
Currently, official documents do not specify all the information required for registration, nor do they clarify whether intermediary agencies need to regularly submit client lists, application materials, financial situations, and transaction records.
Ms. Ma, a Shanghai immigration consultant, stated to Dajiyuan that her company and employees have already completed registration. She said, “We have to register details such as when the company was established, how many current customers we have, and the client data must meet government standards. All our existing client lists have to be submitted for review, if intermediaries are found to have falsified data for clients, the company may have its business license revoked; and if it constitutes a crime, criminal liability will be pursued.”
Articles 12 and 13 of the new regulations stipulate that non-compliant institutions can be fined, ordered to suspend related operations, or shut down for rectification. If they refuse to correct or the situation is severe, relevant business permits or licenses may be revoked. Article 17 stipulates that in cases of a crime, criminal liability will be pursued according to law.
Ms. Ma mentioned that after the publication of the new regulations, many clients voluntarily retrieved their data and terminated their contracts, resulting in a decrease in the company’s business volume. She noted, “After the new regulations were announced, many clients in Shanghai requested to retrieve their data and terminate the contracts, not even wanting the deposits back. Previously, we received dozens of calls for consultation services and fees daily; now it’s just a few. Clients are worried about us submitting their data. One client who originally planned to immigrate to Australia said she’s not going anymore and requested us to delete her records from the computer. Out of respect for the client’s wishes, we deleted her data.”
Mr. Wang, a lawyer in Shanghai, told Dajiyuan that currently, it is explicitly the intermediary agencies and their employees that need to register, not all immigrant applicants. The new regulations also do not publicly specify that intermediary agencies must submit all client data to the government. He stated, “However, the authorities’ operations are not transparent, and intermediaries won’t disclose these details to clients in order to profit. Intermediaries have become an important part of the authorities’ investigation into immigrant families, such as who is planning to immigrate, whether there are state-owned enterprise executives, financial sector personnel, engineers in the technology field, or individuals in sensitive positions.”
Mr. Wang also mentioned that many wealthy individuals have already immigrated abroad several years ago, and there are also many people who bypass intermediaries and directly apply online to foreign immigration departments. “These are a group of people that the authorities temporarily cannot track through intermediaries. Some have obtained foreign status but have been living in the country for a long time. After the new regulations take effect on September 15th, their identities and exit situations may be disclosed during border inspections.”