Business Travel to China from 15 September: The Exit Ban Is Not About You

Hello, this is Ryuta Hamamoto from TIMEWELL.

China's new exit and entry regulations, State Council Order No. 841, took effect on 15 September 2026. I wrote this piece in August, before the effective date, and updated it on 29 October with what has been confirmed since. I also wrote an earlier piece that read the Order from an export control angle.

After it went out, a colleague raised a different one. "Doesn't this affect the people we send to China?" It does. But when I went back to the text, I found this is a story shaped to be misunderstood. Left alone, it turns into "from 15 September your people might not be able to leave China."

Let me get the conclusion out first. That is wrong. It is still wrong now that the Order is in force.

Update after the effective date (as of 29 October 2026)

First, a table of what has changed since the August version and what I have newly confirmed. Sources are the Chinese government (State Council Gazette) and the Chinese Embassy in Japan¹²³⁴.

Item	August version	As of 29 October 2026
Effective date	Due 15 September	In force since 15 September 2026. Article 19 reads 「本规定自2026年9月15日起施行」. Also published in the State Council Gazette, issue 22 of 20261
Exit restriction	Article 4 covers Chinese citizens	Unchanged. The Order still contains no provision restricting the exit of foreign nationals
Entry ban (Article 5)	False materials or statements: one to five years	Text unchanged. I could not find any published case of Article 5 being applied since the effective date
Intermediary filing	Agencies operating before the effective date file within 90 days (the first version mentioned this near Article 8)	The filing rule is Article 7; the deadline is 90 days from the effective date, which I count as about 14 December 2026 (our calculation)1
Invitation letters	Not covered	Article 3(3): whoever issues an invitation letter or other supporting materials is responsible for their truthfulness and must cooperate with verification1
Visa exemption	Not covered	Holders of Japanese ordinary passports travelling for business, trade, tourism and similar purposes for up to 30 days are exempt from an entry visa. The exemption is extended to 24:00 on 31 December 20262. I could not find a published position for 2027 onward
Visa fees	Not covered	From applications accepted on 14 September 2026, the fees for Japanese nationals changed (single entry JPY 16,750; double JPY 25,100; six-month multiple JPY 33,500; one-year multiple JPY 50,250). Applications accepted before that date keep the old fees. The notice does not state the old amounts, so I cannot give the difference3
Arrival card	Not covered	Since 20 November 2025 the card can be completed online before arrival; a paper card is still accepted4

What follows is my own reading. Even on a visa-exempt trip, Article 5(1) covers false statements made when applying for entry at the port of entry (「在口岸申请入境时」)⁵. I could not find an official interpretation of whether the arrival card counts as such a statement. My view is that "visa-exempt" is not a reason to treat the paperwork lightly.

The Japanese Ministry of Foreign Affairs' alert on the Counter-Espionage Law (issued 22 July 2025), which I cite below, has no update that I could confirm⁶. I also could not find a MOFA spot notice dealing with Order No. 841 itself as of 29 October 2026 (checked through search; I could not retrieve the MOFA site directly).

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Starting with the misunderstanding

The exit restriction sits in Article 4, and it opens like this:

中国公民有下列情形之一的，不准出境⁵

Chinese citizens. The third paragraph of that article, the one triggered by violations of export control or technology import-export administration, has the same subject. Nowhere in the nineteen articles of Order No. 841 is there a provision restricting the exit of foreign nationals. I checked the version published by the Ministry of Commerce, the full text released by Xinhua and the version carried by People's Daily against each other⁵.

So there is no sense in which 15 September makes it newly possible to stop a Japanese or other foreign traveller from leaving. What the Order newly enables, in terms of stopping people, concerns Chinese citizens. The case of a Chinese national engineer being unable to travel is covered in reading Order No. 841 from an export control angle.

Does that mean travellers are unaffected? No. The part that reaches them is on the other side: entry.

What Order No. 841 does to foreign nationals

Two provisions matter.

The first is Article 5, in three paragraphs. The first reads:

外国人在境外申请办理中国签证或者在口岸申请入境时提供虚假材料、作出虚假陈述的，移民管理机构、签证机关可以决定1年至5年以内不准其入境。⁵

Where a foreign national submits false materials or makes false statements when applying for a Chinese visa abroad, or when applying for entry at a port, the immigration and visa authorities may impose an entry ban of one to five years.

I suspect this is handled loosely in most companies. Purpose of travel, places to be visited, employment history. Plenty of organisations leave the form to a travel agency or a local fixer and never have the traveller check the final version. "Roughly right" on a form now sits upstream of a potential five-year exclusion. That is not a criticism of the people doing the paperwork. Working at that level of precision has been normal.

The second paragraph covers criminal punishment for obstructing border administration, or administrative punishment for fraudulently obtaining travel documents or unlawful entry and exit, with the same one-to-five year ban running from completion of the punishment⁵.

The third paragraph is the genuinely new part:

外国人被列入反制清单、不可靠实体清单、恶意实体清单或者被采取反制和限制措施等，需要依法采取不予签发出境入境证件或者不准入境等相关措施的，由移民管理机构、签证机关按照职责实施。⁵

Where a foreign national is placed on a countermeasure list, the unreliable entity list or a malicious entity list, or is made subject to countermeasures and restrictive measures, and visa refusal or entry denial needs to be applied, the immigration and visa authorities implement it as part of their duties. Lists and the border desk are now connected in the text.

The other provision is Article 3. It requires the stated reason for entry, exit, stay or residence to be genuine and lawful, and provides that when verifying identity and stated purpose the authorities may ask questions and require the person to produce documents, materials and 电子数据 — electronic data — and other information⁵. Having electronic data named explicitly is not a small thing for anyone crossing a border with a laptop. I wrote about devices and data handling in the Counter-Espionage Law and the National Intelligence Law, so I will not repeat it here.

Article 8, separately, does not permit foreign enterprises and organisations to provide exit and entry intermediary services inside China. For domestic intermediaries, Article 7 requires those already operating before the effective date to file within 90 days of it, about 14 December 2026⁷¹. Worth knowing who handles your local arrangements before that deadline. Under Article 3(3), the invitation letter your Chinese host issues is also subject to verification of its truthfulness, so it pays to align its content with the host, especially for documents the traveller does not write.

If you also want to check whether technical information travels with your people, the free export control readiness check will show you where you stand.

The exit ban has been on the books for thirteen years

Can a foreign national be barred from leaving China? Yes. Just not under Order No. 841.

The provision is Article 28 of the Exit and Entry Administration Law, adopted on 30 June 2012 by the 27th session of the Standing Committee of the 11th National People's Congress and in force since 1 July 2013⁸. Thirteen years old.

第二十八条 外国人有下列情形之一的，不准出境： （一）被判处刑罚尚未执行完毕或者属于刑事案件被告人、犯罪嫌疑人的… （二）有未了结的民事案件，人民法院决定不准出境的； （三）拖欠劳动者的劳动报酬，经国务院有关部门或者省、自治区、直辖市人民政府决定不准出境的； （四）法律、行政法规规定不准出境的其他情形。⁸

The one I would watch is (2). An unresolved civil case where a people's court decides to bar exit. Not a criminal matter. A contract dispute with a counterparty, unpaid invoices, an argument over unwinding a joint venture. If that is live and your person is on the ground when the other side applies for preservation measures, exit can stop.

The awkward part is that once it happens, your options are thin. The bar stays until the dispute resolves or the decision is lifted. How you support someone stranded, what you tell their family, how you rebuild a chain of command. Not the kind of problem to start thinking about on the day.

Which is why the control has to sit before departure. Legal keeps a list of matters in dispute with Chinese counterparties, and any travel request from someone involved in one of those matters gets held for a check. That is the whole mechanism. If you already track matters, it starts as one extra field on the travel request form asking whether the traveller is involved in a dispute with a Chinese counterparty.

Confusing this with Order No. 841 sends the response in the wrong direction. Reading the Order closely does nothing about Article 28. Conversely, linking live disputes to travel approval is something you can build now, without waiting for September.

When the company is listed, it reaches the individual

One more layer. Article 10 of the Provisions on the Unreliable Entity List (MOFCOM Order No. 4 of 2020, in force 19 September 2020) sets out the measures available against a listed foreign entity, and includes these:

（三）限制或者禁止其相关人员、交通运输工具等入境 （四）限制或者取消其相关人员在中国境内工作许可、停留或者居留资格⁹

Restricting or prohibiting the entry of its relevant personnel and means of transport; restricting or revoking their work permits, stay or residence status in China. The entity is listed, but the measures reach people. Article 5(3) of Order No. 841 reads as putting the resulting visa refusals and entry denials into the hands of the immigration and visa authorities as a matter of duty.

One thing to state plainly. Being on a list does not mean the company did anything wrong. It is a regulatory designation, not a judgement on the company, and legitimate civilian businesses do get caught by broad categories.

Also, the "control list" and "watch list" on which Japanese companies were placed by the Chinese measures of 2026 belong to the export control framework and are a different instrument from the unreliable entity list discussed here. Conflating them produces a false picture of the companies named. The measures themselves are covered, from primary sources, in the expert panel on economic security.

Before, during, after

Making this operational.

Before. Have the traveller check the visa application themselves: purpose, places to be visited, employment history. Do not file the agency's draft unread. On a visa-exempt trip, keep the same account of purpose and host ready, because it can be asked at the port of entry. That is where Article 5(1) bites. Have legal confirm there is no live civil dispute with a Chinese counterparty on the matters this person handles, which is how you address Article 28(2). Send a travel-only device carrying the minimum data needed. With Article 3 naming electronic data explicitly, designing for the request rather than hoping it does not come is the straightforward reading.

During. Japan's Ministry of Foreign Affairs has published spot information that is unusually specific here. "Alert relating to China's Counter-Espionage Law," issued 22 July 2025, is still posted as current⁶. Entering or photographing military restricted and military administrative zones; unauthorised land surveys; GPS surveying, geological work such as hot spring drilling, ecological surveys and archaeological surveys; unauthorised statistical surveys by foreign nationals. It states that even distributing an academic questionnaire can fall foul of the Statistics Law⁶. The line I found heaviest is this one:

Conduct of the above kinds may be investigated not only where it is recent, during the current stay in China, but also where it is past conduct, during earlier stays in China or conduct outside China⁶

Not doing anything on this trip is not the test.

After. Plan later travel on the assumption that records generated locally can be consolidated. On what gets recorded, I worked through the reported cases using only the confirmed facts in reading the foreign personnel platform reporting.

The August reports of detained Japanese nationals

In August it was reported that several Japanese nationals are being held in China, on suspicion said to relate to China's export controls on dual-use items, including rare earths, aimed at Japan¹⁰. Detention is an investigative measure. It does not mean guilt has been established and is not a judgment on any company. Neither the individuals' accounts nor an official Chinese explanation could be confirmed from the reporting. This is separate from the entry and exit rules discussed here, but the two share one point: what you carry or transfer in China can engage China's export controls as well as Japan's. I set out how to read the reports in How to read the reports of detained Japanese nationals in China.

What changed on 15 September, and what did not

Entry changed. Under Article 5 of Order No. 841, false materials or statements in a visa application or at entry, and punishment for obstructing border administration and related offences, each carry an entry ban of one to five years. List placement and countermeasures are now connected in the text to the visa and border desks. Article 3 makes the demand for electronic data explicit.

Exit did not. The exit restriction in Order No. 841 applies to Chinese citizens, and the Order has no provision restricting the exit of foreign nationals. The basis on which a foreign traveller can be barred from leaving is Article 28 of the Exit and Entry Administration Law, in force since 2013.

Keeping those apart keeps the response in the right order. The entry side is about how visa applications are actually filled in, and the team that handles travel arrangements can start this week. The exit side is about linking live disputes to travel approval, and that is legal's job. Different owners. Compress it all into "travel to China is risky" and neither of them moves.

What nags at me is that changes like this rarely reach the desk where the forms are filled in. Your export control team can read Order No. 841 closely and it still will not reach the person typing the visa application, if that person sits in another department. For this one, working out who actually writes the form may be the single most effective place to start.

If you want to review your programme, including technical information handling and counterparty screening, TRAFEED may be a useful reference point, and you can bring a specific situation to us here.

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Footnotes

1. Regulations of the State Council on Exit and Entry Administration (State Council Order No. 841), full text. Article 3(2) allows the authorities to require electronic data and other materials; Article 3(3) provides that 「单位或者个人为出境入境人员出具邀请函件或者其他申请材料的，应当对邀请内容和证明事项的真实性负责，并配合移民管理机构、签证机关核实有关信息」; Article 7 covers filing for exit and entry intermediary services (its transitional rule: 「本规定施行前已经从事出境入境中介服务的，应当在本规定施行之日起90日内办理备案手续」); Article 19 reads 「本规定自2026年9月15日起施行」. Central People's Government of China (State Council Gazette, issue 22 of 2026): https://www.gov.cn/gongbao/2026/issue_12906/202608/content_7077791.html and MOFCOM's published text: https://fec.mofcom.gov.cn/article/ggfw/crjfw/crjzcwj/202607/7209.html . The date 90 days after the effective date is our calculation. ↩ ↩² ↩³ ↩⁴ ↩⁵

2. Embassy of the People's Republic of China in Japan, "Notice on extending the unilateral visa exemption policy" (published 16 December 2025, Japanese). It extends to 24:00 on 31 December 2026 the exemption from entry visas for holders of ordinary passports of listed countries, including Japan, who stay in China for up to 30 days for business or trade, tourism, family visits, exchange or visits, or transit. Others still need a visa before entry. https://jp.china-embassy.gov.cn/jpn/lszc/hzqzyw/202512/t20251216_11774313.htm ↩ ↩²

3. Embassy of the People's Republic of China in Japan, "Notice on changes to visa fees" (11 September 2026, Japanese). States that fees for applicants of Japanese nationality change from 14 September 2026: single entry JPY 16,750, double entry JPY 25,100, six-month multiple JPY 33,500, one-year multiple JPY 50,250. Applications accepted before 14 September and visas for third-country nationals keep the old fees. https://jp.china-embassy.gov.cn/jpn/tztg/202609/t20260911_12020422.htm ↩ ↩²

4. Embassy of the People's Republic of China in Japan, "Notice on online declaration of the foreigner arrival card" (9 December 2025, Japanese). From 20 November 2025, foreigners can declare arrival card information online before arriving, through the National Immigration Administration website, the "Immigration 12367" app and others. Declaration on arrival and the paper card are also accepted; permanent residence permit holders, group visa entrants, E-Channel users and others are exempt from declaring. https://jp.china-embassy.gov.cn/jpn/tztg/202512/t20251209_11769194.htm ↩ ↩²

5. 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, signed by Premier Li Qiang and issued 22 July 2026, effective 15 September 2026, 19 articles. Article 4 sets out grounds for barring exit and applies to Chinese citizens. Article 5(1) reads: 「外国人在境外申请办理中国签证或者在口岸申请入境时提供虚假材料、作出虚假陈述的，移民管理机构、签证机关可以决定1年至5年以内不准其入境。」 Article 5(2) provides a one-to-five year entry ban from completion of punishment for criminal punishment for obstructing border administration or administrative punishment for fraudulently obtaining travel documents or unlawful exit and entry. Article 5(3) reads: 「外国人被列入反制清单、不可靠实体清单、恶意实体清单或者被采取反制和限制措施等，需要依法采取不予签发出境入境证件或者不准入境等相关措施的，由移民管理机构、签证机关按照职责实施。」 Article 3 provides that the stated reason must be genuine and lawful and that the authorities may 「询问相关情况，要求其出示、提供有关文件、资料、电子数据等信息」. Article 8 does not permit foreign enterprises and organisations to provide exit and entry intermediary services within China. The Order contains no provision restricting the exit of foreign nationals. Ministry of Commerce text: https://fec.mofcom.gov.cn/article/ggfw/crjfw/crjzcwj/202607/7209.html — full text via Xinhua: https://www.news.cn/20260731/08228229f320402fb3a97a095abfd1ad/c.html ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷

6. Ministry of Foreign Affairs of Japan, Overseas Safety Website, spot information "China: Alert relating to China's Counter-Espionage Law" (issued 22 July 2025; posted as current information at the time of writing). The enactment of the Counter-Espionage Law in 2014 and its revision in April 2023, the amendment of the Law on Guarding State Secrets in May 2024, the confirmation that 17 Japanese nationals have been detained by Chinese authorities on offences relating to "national security" since 2014 with five still detained, the prohibition under the Law on the Protection of Military Facilities of unauthorised entry into and photography of military restricted zones and military administrative zones, the risk of detention arising from unauthorised land surveys and from collecting geographic information through GPS surveying, geological work such as hot spring drilling, ecological surveys and archaeological surveys, the possibility that merely possessing a map (including a hand-drawn one) may be treated as falling within scope, the prohibition under the Statistics Law of unauthorised statistical surveys by foreign nationals including academic sample surveys, and the statement that conduct may be investigated not only where recent but also where it occurred during earlier stays in China or outside China, are all from this spot information. https://www.anzen.mofa.go.jp/info/pcspotinfo_2025C029.html ↩ ↩² ↩³ ↩⁴

7. Press briefing by officials of the Ministry of Justice, the Ministry of Public Security and the National Immigration Administration on the Regulations. The four areas covered and the transitional rule requiring intermediary agencies already operating before the effective date to file within 90 days are from this briefing. https://www.nia.gov.cn/n741440/n741577/c1793235/content.html ↩

8. Exit and Entry Administration Law of the People's Republic of China. Adopted 30 June 2012 at the 27th session of the Standing Committee of the 11th National People's Congress; in force 1 July 2013. Article 28 lists as grounds for barring a foreign national from exit: (1) an unserved criminal sentence, or status as a defendant or suspect in a criminal case (excluding transfer of sentenced persons under applicable agreements between China and a foreign state); (2) an unresolved civil case where a people's court has decided to bar exit; (3) unpaid wages to workers where the relevant department of the State Council or a provincial-level people's government has decided to bar exit; and (4) other circumstances provided by laws and administrative regulations. Text as published by the Shanghai Municipal People's Government: https://www.shanghai.gov.cn/grgzxkgjj/20240922/ec55b54b16a2443fa9f099719a74a3ca.html ↩ ↩²

9. Provisions on the Unreliable Entity List (MOFCOM Order No. 4 of 2020, issued and in force 19 September 2020), Article 10, listing the measures that may be taken against a listed foreign entity: (1) restricting or prohibiting import and export activities relating to China; (2) restricting or prohibiting investment within China; (3) 「限制或者禁止其相关人员、交通运输工具等入境」; (4) 「限制或者取消其相关人员在中国境内工作许可、停留或者居留资格」; (5) fines according to the seriousness of the circumstances. https://dcj.mofcom.gov.cn/article/zcfb/zcblgg/202009/20200903002593.shtml — the unreliable entity list under these Provisions is a separate instrument from the control list and watch list operated under the export control framework. ↩

10. Mainichi Shimbun, report on the detention of several Japanese nationals in China (11 August 2026, Japanese). That two Japanese employees of a major heavy-electrical group were reportedly detained in Dalian, Liaoning in May over the carrying out of rare-earth-related products, and that the suspicion is said to relate to China's export controls on dual-use items including rare earths aimed at Japan, are from that report. It names no company or individual and carries no official explanation from the Chinese side. Detention is an investigative measure and does not mean guilt is established or amount to a judgment on any company. ↩