National Security, State Secrets, and Foreign Activities in China: Legal Restrictions, Espionage Risks, and Compliance Obligations

Introduction

National security has become an increasingly important organising principle of Chinese law. It influences the regulation of foreign investment, scientific research, data processing, international cooperation, journalism, education, civil society activities, and the conduct of individuals and organisations operating in China. Foreign nationals and foreign-invested enterprises are therefore subject not only to ordinary rules governing commercial and personal activities, but also to a legal framework designed to protect the sovereignty, security, development interests, and political stability of the People’s Republic of China.

China’s national security framework is not contained in a single statute. It consists of constitutional principles, national security legislation, criminal law, administrative regulations, cybersecurity and data protection rules, foreign investment controls, and legislation governing foreign organisations. Several important laws have been adopted or substantially revised in recent years. These include the Counter-Espionage Law, revised in 2023; the Law on Guarding State Secrets, revised in 2024; the Regulations on Network Data Security Management, effective from January 2025; and the Cybersecurity Law, amended in October 2025 and effective from 1 January 2026.

These developments have practical consequences for foreign businesses, researchers, consultants, employees, journalists, academics, non-governmental organisations, and visitors. Activities that may appear routine in other jurisdictions—such as collecting commercial information, conducting market research, mapping infrastructure, transferring company records overseas, interviewing local contacts, or participating in research projects—may require particular care when undertaken in China. The legal significance of an activity depends on its subject matter, purpose, methods, the information obtained, the persons involved, and whether it falls within a regulated or restricted area.

It is nevertheless important to distinguish between national security regulation and a general prohibition on foreign activity. China permits extensive international trade, investment, education, tourism, academic exchange, and professional cooperation. Foreign individuals and organisations may conduct many activities lawfully, provided that they comply with the applicable registration, licensing, confidentiality, data protection, and other regulatory requirements. The existence of national security legislation does not mean that every foreign commercial or research activity is suspicious or prohibited.

This article examines the principal laws governing national security, state secrets, counter-espionage, foreign organisations, sensitive information, and international business activities in China. It also explains the practical risks that foreign individuals and organisations should consider when conducting activities in the country. The discussion is educational and general in nature. It does not replace advice from qualified Chinese legal professionals on a particular transaction, investigation, or regulatory matter.

1. The Constitutional and Legal Foundations of National Security

1.1 National security as a constitutional responsibility

The Constitution of the People’s Republic of China establishes the protection of national sovereignty, unity, territorial integrity, and state security as fundamental responsibilities of the state. It also establishes duties relating to the protection of national interests and the observance of Chinese law.

Article 28 provides that the state maintains public order, suppresses treasonous and other counter-revolutionary activities, and punishes conduct that endangers public security or disrupts the socialist economic system. Other constitutional provisions establish the responsibilities of state institutions and the duties of citizens in relation to national security and national interests.

The Constitution also recognises the lawful rights and interests of foreigners. Article 32 provides that the People’s Republic of China protects the lawful rights and interests of foreigners within its territory and that foreigners in China must abide by Chinese law. This principle is important because national security legislation operates within a broader legal framework that recognises both state interests and the legal position of individuals and organisations.

Foreign nationals do not acquire immunity from Chinese law merely because their conduct involves an international employer, a foreign government, an overseas organisation, or a transaction arranged outside China. Conversely, foreign nationality alone does not make an individual subject to criminal suspicion or establish liability. Legal responsibility must arise from conduct falling within the applicable legal provisions.

1.2 The National Security Law

The National Security Law, adopted in 2015, provides a broad statutory framework for the protection of national security. It defines national security in terms of the relative absence of threats to the state’s political power, sovereignty, unity, territorial integrity, people’s welfare, sustainable economic and social development, and other major national interests.

The law adopts a comprehensive understanding of national security. Its subject matter extends beyond military defence and espionage to include political, economic, cultural, social, technological, ecological, resource, information, and other areas.

This broad approach is relevant to foreign organisations because an activity may be assessed not only by reference to traditional criminal offences but also by reference to the wider statutory framework governing national security and public interests.

The National Security Law establishes responsibilities for state institutions, enterprises, social organisations, and individuals. It also provides a framework for national security education, supervision, coordination, and the handling of security-related matters.

Foreign nationals and organisations must therefore consider national security requirements when conducting activities in China, particularly where those activities involve sensitive infrastructure, government institutions, strategic industries, important data, or regulated information.

1.3 The Counter-Espionage Law

The Counter-Espionage Law is one of the most significant statutes for foreign individuals and organisations.

Originally adopted in 2014, it was substantially revised on 26 April 2023. The revised law entered into force on 1 July 2023. It expands and clarifies the legal framework governing the prevention, investigation, and punishment of espionage-related conduct.

The law identifies state security organs as the competent authorities responsible for counter-espionage work. Public security authorities, departments responsible for state secrets, and relevant military authorities cooperate within their respective areas of responsibility.

The revised law also places greater emphasis on preventive obligations. Organisations and institutions are expected to establish security precautions, educate employees, and cooperate with lawful counter-espionage activities.

The legislation is particularly relevant to foreign businesses and researchers because its definition of espionage is not confined to the conventional image of a person secretly collecting military plans for a foreign intelligence service. It also covers specified activities involving the unlawful acquisition, purchase, or provision of state secrets, intelligence, and other documents, data, materials, or articles related to national security or interests.

This does not mean that ordinary research, market analysis, or information gathering automatically constitutes espionage. The legal character of an activity depends on the statutory elements and the surrounding circumstances. However, the breadth of the law makes it important to assess the subject matter and methods of information collection before undertaking work involving sensitive sectors.

1.4 The Foreign Relations Law

The Foreign Relations Law, adopted on 28 June 2023, provides another important element of the legal framework.

Article 38 recognises the protection of lawful rights and interests of foreign nationals and foreign organisations in China. It also provides that the state has authority to permit or deny entry, stay, or residence and to regulate activities conducted within China by foreign organisations.

Foreign nationals and foreign organisations operating in China must comply with Chinese law and must not endanger national security, undermine social and public interests, or disrupt social and public order.

The law should be read together with the legislation governing immigration, foreign investment, non-governmental organisations, data, cybersecurity, and criminal responsibility. It does not independently make every foreign activity subject to special approval. Rather, it confirms the state’s regulatory authority over foreign relations and foreign activities within the country.

2. The Meaning and Scope of Espionage Under Chinese Law

2.1 The statutory definition

The 2023 Counter-Espionage Law identifies several categories of conduct that may constitute espionage.

These include activities that endanger national security and are carried out by espionage organisations or their agents, or by persons acting under their direction, instigation, or funding. The law also addresses joining an espionage organisation, accepting tasks assigned by such an organisation or its agents, and cooperating with them in activities that endanger national security.

A further important category concerns the unlawful acquisition or provision of state secrets, intelligence, or other documents, data, materials, or articles related to national security or interests.

The law covers certain conduct involving overseas institutions, organisations, and individuals, as well as domestic actors who cooperate with them in the relevant circumstances.

The statutory language is broader than the traditional concept of espionage based exclusively on the theft of classified military information. It reflects the modern importance of information, technology, infrastructure, and economic security.

Nevertheless, the legal definition must not be confused with ordinary contact between Chinese and foreign persons. International business cooperation, academic collaboration, professional communication, and the exchange of publicly available information are not automatically espionage.

2.2 Information connected with national security or interests

The revised law refers not only to formally classified state secrets but also to intelligence and other materials related to national security or interests.

This distinction matters. A person should not assume that information is legally unrestricted merely because it is not visibly marked as classified. Nor should every commercially sensitive or technical document be treated as a state secret.

The legal assessment may depend on the nature of the information, its source, the circumstances in which it was obtained, whether it has been lawfully disclosed, and whether its acquisition or provision falls within the relevant statutory definition.

For example, collecting publicly available information about a company’s products is fundamentally different from obtaining restricted technical documentation through unauthorised access or through a person who is prohibited from disclosing it.

Similarly, studying publicly released transport statistics differs from secretly obtaining restricted information concerning the operation or security of strategic infrastructure.

2.3 The role of purpose, conduct, and context

The purpose of an activity may be relevant, but a person’s stated purpose does not necessarily determine its legal classification.

An individual may describe an activity as commercial research, academic work, journalism, or due diligence. Those descriptions do not automatically establish that the methods used were lawful. Conversely, the fact that research concerns a sensitive subject does not, by itself, establish criminal conduct.

Authorities may examine the source of information, the methods of collection, communications with other persons, financial arrangements, the nature of the materials obtained, and the intended recipient.

Foreign organisations should therefore ensure that their employees, consultants, and contractors understand the distinction between lawful research and unauthorised acquisition of restricted information.

2.4 Espionage and ordinary commercial intelligence

Commercial intelligence is a normal part of international business. Companies routinely collect information about competitors, markets, supply chains, prices, consumer preferences, regulatory developments, and public investment plans.

Chinese law does not prohibit all commercial intelligence gathering. However, information collection must comply with applicable laws, including the Counter-Espionage Law, Criminal Law, Data Security Law, Personal Information Protection Law, Cybersecurity Law, and rules governing trade secrets and commercial confidentiality.

Foreign businesses should avoid obtaining information through deception, unauthorised access, bribery, coercion, or the exploitation of employees who have access to restricted government or corporate materials.

The fact that a foreign company is conducting due diligence does not create an exemption from national security requirements.

3. State Secrets: Classification, Protection, and Disclosure

3.1 The Law on Guarding State Secrets

The Law on Guarding State Secrets is the central statute governing the classification, protection, handling, and disclosure of state secrets.

The law was originally adopted in 1988 and revised in 2010. A further substantial revision was adopted on 27 February 2024 and entered into force on 1 May 2024.

The revised legislation reflects the increasing importance of digital information, electronic communications, network systems, and the circulation of information across organisations and borders.

The law establishes a system under which information meeting the statutory criteria may be classified as a state secret through legally prescribed procedures. It also imposes duties on institutions and individuals who have access to such information.

The implementing regulations were revised in 2024 and entered into force on 1 September 2024. They provide additional detail concerning classification, management responsibilities, personnel safeguards, information systems, and supervision.

3.2 What constitutes a state secret?

Under the law, state secrets concern matters that have a vital bearing on state security and national interests and are classified in accordance with prescribed procedures for access by a limited group of persons during a specified period.

The statutory categories include matters concerning:

• Major policy decisions relating to state affairs;
• National defence and armed forces activities;
• Diplomatic activities and foreign relations;
• National economic and social development;
• Science and technology;
• Activities concerning national security investigations and the prevention of crimes;
• Other matters designated as state secrets under the law.

The categories are broad, but classification is not simply a matter of labelling any sensitive information as secret. The law provides a formal classification system, including rules governing the authority to classify information, the determination of secrecy levels, and the duration of protection.

3.3 Classification levels

Chinese law recognises three principal levels of state secrets:

1. Top secret – information whose disclosure would cause especially serious harm to state security and national interests.
2. Secret – information whose disclosure would cause serious harm.
3. Confidential – information whose disclosure would cause harm.

The classification level determines the degree of protection required and the restrictions governing access, storage, transmission, and use.

The classification system is significant for foreign organisations because access to information may be restricted even where an individual has a legitimate professional reason to request it.

A foreign employee, consultant, or researcher should not assume that professional status, contractual authorisation, or a general business relationship grants access to classified material.

3.4 Classification, declassification, and responsibility

The revised law clarifies responsibilities for determining, managing, reviewing, and protecting state secrets. It also addresses the procedures for changing or removing classification where the legal conditions are satisfied.

Classification is not necessarily permanent. The law provides for time limits and review, and information may be declassified when the relevant conditions are met.

However, the expiration of an expected classification period should not be assumed without verification. Nor should an individual independently decide that information has become public merely because it is old, widely discussed, or appears in unofficial publications.

Foreign organisations should rely on authorised disclosures and appropriate confirmation rather than making their own assumptions about the status of potentially classified material.

3.5 Duties of persons and organisations

The obligation to protect state secrets is not confined to government employees.

The law imposes responsibilities on state organs, enterprises, public institutions, social organisations, and individuals. Private companies may therefore have obligations where their activities involve classified information or work connected with state-secret protection.

Relevant duties may include:

• Preventing unauthorised access;
• Restricting access to persons with the appropriate authorisation;
• Using approved systems and storage arrangements;
• Protecting documents and electronic information;
• Preventing unauthorised copying, transmission, or publication;
• Reporting suspected leaks or security incidents;
• Cooperating with lawful supervision and investigations.

The revised law also strengthens the treatment of information throughout its digital lifecycle. The production, copying, publication, transmission, and dissemination of information containing state secrets must comply with applicable confidentiality requirements.

3.6 Work secrets are not identical to state secrets

An important distinction in the revised framework concerns work secrets.

Work secrets generally refer to information generated or obtained in the performance of public duties which, if disclosed, could adversely affect the normal conduct of official activities or the interests of the relevant state organ or public institution.

Work secrets are not automatically state secrets. They belong to a separate category of protected official information.

This distinction matters because not every non-public government document is necessarily classified as a state secret. Nevertheless, the fact that information is not formally classified does not mean that it can be freely disclosed or transferred.

Foreign organisations dealing with government departments, public institutions, or state-owned enterprises should establish the permitted uses of documents received and avoid assuming that access for one purpose authorises publication or onward transmission.

4. The Legal Position of Foreign Nationals and Foreign Organisations

4.1 Application of Chinese national security laws to foreigners

Foreign nationals present in mainland China are subject to Chinese law. The relevant national security statutes do not generally provide a blanket exemption for foreign citizens, overseas employees, foreign-invested enterprises, or international organisations.

The Counter-Espionage Law expressly addresses certain activities by overseas institutions, organisations, and individuals. Its implementing rules also clarify that the relevant concept of an overseas individual includes a person residing in China who does not possess Chinese nationality.

Foreign nationality therefore does not prevent the application of counter-espionage legislation where the statutory requirements are met.

At the same time, foreign nationals retain lawful rights under Chinese legislation. Article 32 of the Constitution and Article 38 of the Foreign Relations Law recognise the protection of lawful rights and interests of foreigners within China.

The legal position is consequently not one of unrestricted foreign activity or automatic suspicion. It is one of regulated participation subject to the same applicable legal framework.

4.2 Foreign organisations operating in China

Foreign organisations may be subject to specific registration and supervision requirements depending on their legal form and activities.

The Foreign Non-Governmental Organisations Law, adopted in 2016, governs the activities of overseas non-governmental organisations within mainland China.

The law defines foreign non-governmental organisations broadly to include foundations, social groups, think tanks, and other non-profit, non-governmental social organisations lawfully established outside China.

It permits qualifying organisations to conduct activities in areas such as:

• Economics;
• Education;
• Science and technology;
• Culture;
• Health;
• Sports;
• Environmental protection;
• Poverty alleviation;
• Disaster relief.

However, the law establishes a registration and filing system. A foreign NGO generally must register a representative office in China or complete the required filing for temporary activities before undertaking activities within the country.

Foreign NGOs are prohibited from conducting or funding profit-making activities, political activities, or unlawful religious activities under the statute. They must also comply with Chinese law and must not endanger national unity or security or harm national or public interests.

4.3 Registration and supervision of foreign NGOs

The Ministry of Public Security and provincial-level public security authorities act as registration and administration authorities under the Foreign NGOs Law. Relevant Chinese departments may serve as professional supervisory units.

A foreign organisation seeking to establish a representative office must satisfy statutory conditions, including lawful establishment abroad, the capacity to bear civil liability, a qualifying non-profit purpose, and a sufficient period of substantive activity outside China.

Temporary activities are subject to a separate filing procedure and must be conducted in cooperation with an eligible Chinese partner organisation.

The legal framework is particularly important for international foundations, research institutes, educational organisations, charities, and professional associations.

An organisation should not assume that its overseas registration automatically authorises it to operate in China. Nor should it assume that a local commercial partner can lawfully undertake activities on its behalf without the required registration or filing.

4.4 Foreign companies and commercial enterprises

Ordinary foreign-invested companies are not generally regulated as foreign NGOs. Their legal status is determined by company law, foreign investment legislation, sector-specific regulations, and other applicable rules.

However, commercial status does not exclude national security obligations.

A foreign-invested enterprise may be subject to requirements relating to data security, state secrets, critical information infrastructure, export controls, technology transfer, national security review, and cooperation with competent authorities.

A company may also become involved in a national security matter through its employees, suppliers, consultants, data systems, or contractual relationships.

Foreign investors should therefore distinguish between the rules governing the establishment of a business and the continuing compliance obligations arising from its operations.

5. Sensitive Activities and Areas Requiring Particular Care

5.1 Military facilities and defence-related information

Military facilities, defence installations, military transport infrastructure, and certain related locations are subject to special restrictions.

The Law on Guarding State Secrets and other national security legislation protect military information and restrict unauthorised access to military facilities and other protected locations.

Foreign visitors should respect signs, barriers, security instructions, and photography restrictions around military installations and other sensitive sites.

Photographing a publicly accessible civilian building is not automatically unlawful. However, deliberately photographing restricted military facilities, collecting technical details about their operations, or attempting to obtain protected defence information may create legal risks.

The relevant distinction is between ordinary tourism or public photography and conduct involving restricted locations, unauthorised access, or the collection of protected information.

5.2 Infrastructure and strategic industries

Certain infrastructure and industrial sectors may have particular national security significance.

Examples include:

• Energy generation and distribution;
• Telecommunications;
• Transport networks;
• Water supply systems;
• Financial infrastructure;
• Defence-related manufacturing;
• Major digital platforms;
• Certain advanced technology industries;
• Critical information infrastructure.

The importance of a particular asset depends on its function, scale, location, and designation under the relevant legal framework.

Foreign consultants, auditors, engineers, researchers, and investors working in these sectors should determine whether their assignments involve restricted information, regulated data, protected facilities, or critical information infrastructure.

A routine technical assessment may require additional safeguards if it involves network architecture, security vulnerabilities, operational data, or other sensitive information.

5.3 Mapping, surveying, and geographic information

Geographic and surveying activities may be subject to special rules in China.

The collection, processing, publication, and transfer of geographic information can involve regulated surveying and mapping activities. Certain geographic data may also be relevant to national security or state secrets.

Foreign organisations should distinguish between using ordinary commercial maps and undertaking professional surveying, mapping, geospatial data collection, or remote sensing.

Activities involving high-precision geographic information, infrastructure mapping, military-related locations, or restricted areas may require specific authorisations or compliance procedures.

A company should not assume that the use of drones, specialised surveying equipment, satellite imagery, or geospatial databases is unrestricted merely because comparable activities are lawful in another country.

5.4 Academic research and scientific cooperation

China participates extensively in international academic and scientific cooperation. Foreign universities, research institutions, laboratories, and individual scholars may conduct lawful research and exchange information with Chinese counterparts.

Nevertheless, research involving defence technology, advanced computing, telecommunications, biotechnology, energy systems, strategic materials, or other sensitive fields may raise additional legal questions.

The relevant issues may include:

• Whether the research involves state secrets or restricted technical information;
• Whether the institution requires special approval or licensing;
• Whether the research uses regulated equipment or technology;
• Whether data may be transferred outside China;
• Whether foreign funding or cooperation arrangements are subject to registration or reporting;
• Whether the research involves personal information or important data.

Academic freedom and international cooperation should not be confused with unrestricted access to all government, industrial, or technical information.

Researchers should obtain institutional guidance before collecting or transferring sensitive information and should ensure that research agreements accurately identify permitted uses and disclosure restrictions.

5.5 Journalism, interviews, and publication

Foreign journalists and media organisations operate within a regulatory environment that includes immigration, media, publication, confidentiality, and national security requirements.

The collection and publication of information may raise legal issues where it involves unauthorised access to restricted locations, classified information, protected personal information, or other legally restricted materials.

Interviewing a person or reporting on a public event is not automatically espionage. However, a journalist’s professional status does not create a general exemption from laws governing state secrets or restricted information.

Foreign media organisations should ensure that their personnel understand applicable accreditation, visa, publication, and confidentiality requirements.

5.6 Commercial due diligence and investigations

Foreign companies frequently conduct due diligence before investing in Chinese businesses or entering into commercial relationships.

Such work may involve reviewing corporate records, ownership structures, litigation history, regulatory compliance, financial statements, employment arrangements, and supply-chain information.

Lawful due diligence is an ordinary commercial activity. Nevertheless, methods matter.

Companies should avoid obtaining information through unauthorised access, deception, bribery, coercion, or the improper inducement of employees to disclose confidential or restricted material.

They should also distinguish between publicly available corporate information, commercially confidential information, personal information, and information potentially protected by national security legislation.

A due diligence provider should be able to explain the lawful basis for its information sources and the methods used to obtain them.

6. Data Security, Cybersecurity, and Cross-Border Information Transfers

6.1 The Data Security Law

The Data Security Law, adopted on 10 June 2021 and effective from 1 September 2021, establishes a general framework for data security and data processing.

It applies to data processing activities within mainland China. It may also have extraterritorial relevance where processing outside China harms China’s national security, public interests, or the lawful rights and interests of individuals or organisations in China.

The law recognises a classification and categorisation system based on the importance of data and the potential harm arising from its alteration, destruction, disclosure, unlawful acquisition, or misuse.

It distinguishes ordinary data from important data and core state data, which are subject to more stringent protection.

The classification of data is therefore a central compliance issue for foreign companies. An organisation should not assume that all business information is treated identically or that the same transfer rules apply to every category.

6.2 Important data and core data

Important data refers to data in particular sectors, groups, regions, or at a certain level of precision and scale, the compromise of which may directly endanger national security, economic operations, social stability, or public health and safety.

Core data concerns particularly significant areas such as national security, the lifelines of the national economy, major aspects of people’s livelihoods, and important public interests. It is subject to a stricter management system.

The identification of important data may depend on sectoral catalogues and regulatory determinations. Organisations should therefore examine the rules applicable to their industry rather than rely exclusively on their own internal classification systems.

A foreign company collecting industrial, infrastructure, transport, energy, financial, or other potentially sensitive information should assess whether the relevant data falls within a protected category.

6.3 The Personal Information Protection Law

The Personal Information Protection Law (PIPL), effective from 1 November 2021, regulates the processing of personal information.

It applies to personal information processing within China and, in specified circumstances, to processing outside China involving individuals located in China.

The law establishes requirements relating to lawful processing, purpose limitation, necessity, transparency, security measures, individual rights, and cross-border transfers.

Foreign companies may therefore be subject to Chinese personal information requirements even where their headquarters, servers, or service providers are located abroad.

The law also restricts the provision of personal information stored in China to foreign judicial or law enforcement authorities without approval from the competent Chinese authorities, subject to the statutory framework.

This is particularly relevant to multinational companies responding to foreign regulatory investigations, litigation, audits, and disclosure requests.

6.4 The Cybersecurity Law and its 2025 amendment

The Cybersecurity Law is a central part of China’s digital security framework.

Originally adopted in 2016 and effective from 1 June 2017, it was amended on 28 October 2025. The revised law entered into force on 1 January 2026.

The amendment introduces additional provisions concerning the safe development of artificial intelligence, strengthens certain legal responsibilities, and increases penalties for specified cybersecurity violations.

It also expands the law’s extraterritorial reach in relation to overseas activities that endanger China’s cybersecurity.

The law establishes obligations for network operators and critical information infrastructure operators, including security management, technical safeguards, incident response, and cooperation with relevant authorities.

Foreign companies operating networks or digital services in China should review the amended legislation and ensure that their cybersecurity policies reflect the current requirements.

6.5 Regulations on Network Data Security Management

The Regulations on Network Data Security Management, adopted in September 2024 and effective from 1 January 2025, provide additional rules for network data processing.

They supplement the Cybersecurity Law, Data Security Law, and Personal Information Protection Law.

The regulations address data processing activities, personal information protection, important data management, cross-border information transfers, and the responsibilities of network data processors.

They also establish more detailed obligations for certain large online platforms and organisations processing important or core data.

For foreign companies, these regulations reinforce the importance of identifying data categories, documenting processing activities, assessing security risks, and implementing appropriate safeguards.

6.6 Cross-border data transfers

Cross-border data transfers are particularly important for multinational companies.

A Chinese subsidiary may need to transfer employee records, customer information, financial data, technical documents, or operational information to a foreign parent company.

Such transfers cannot be treated as ordinary internal administrative communications without considering the applicable legal requirements.

Depending on the nature and volume of the information, the organisation may need to use one of the legally recognised mechanisms for cross-border personal information transfers, such as:

• A security assessment organised by the competent authorities;
• A standard contract for cross-border personal information transfer;
• Personal information protection certification;
• An applicable statutory exemption or other recognised transfer mechanism.

The applicable requirements depend on the type and volume of personal information, the identity and role of the processor, and whether important data is involved. Regulatory rules and exemptions may also be updated.

The transfer of important data or state secrets raises separate and potentially more restrictive issues. Compliance with personal information transfer requirements does not automatically authorise the transfer of state secrets or other restricted information.

6.7 Foreign disclosure requests and conflicting legal obligations

Multinational companies may face conflicting legal requirements when foreign regulators, courts, or law enforcement agencies request information stored in China.

The Personal Information Protection Law and other Chinese legislation restrict certain disclosures of data stored within China to foreign judicial or law enforcement authorities without approval from competent Chinese authorities.

A company should therefore avoid assuming that a foreign court order or regulatory request automatically authorises disclosure from China.

It should assess the request under both the foreign legal system and the applicable Chinese rules, obtain appropriate legal advice, and determine whether approval or another lawful procedure is required.

This issue is particularly important in cross-border litigation, internal investigations, anti-corruption reviews, competition proceedings, and regulatory audits.

7. National Security Review and Foreign Investment

7.1 The Foreign Investment Law

China’s Foreign Investment Law, effective from 1 January 2020, provides the general framework for foreign investment.

The law recognises the protection of lawful foreign investment and establishes a system for regulating investment activities. However, foreign investment remains subject to national security review in specified circumstances.

The national security review system is intended to assess whether particular foreign investments may affect national security.

It is not simply an ordinary company registration procedure. A transaction may satisfy general corporate and market-access requirements while still requiring a separate national security assessment.

7.2 The national security review mechanism

The Measures for the Security Review of Foreign Investment, effective from 18 January 2021, establish the procedural framework for reviewing certain foreign investment transactions.

The review system applies to specified investment activities involving areas such as:

• Military industry and military-related sectors;
• Military facilities and surrounding areas;
• Important agricultural products;
• Important energy and resources;
• Major equipment manufacturing;
• Important infrastructure;
• Important transport services;
• Important cultural products and services;
• Important information technology and internet products and services;
• Important financial services;
• Key technologies and other important areas related to national security.

The precise scope depends on the relevant statutory and regulatory provisions.

7.3 Notification and review

Foreign investors should determine whether a proposed transaction falls within the national security review framework.

Where notification is required, the parties must submit the prescribed information to the competent mechanism. A transaction may be reviewed, approved subject to conditions, prohibited, or required to be adjusted or unwound, depending on the outcome and applicable rules.

Parties should not assume that closing a transaction before completing a required review will eliminate the legal risk.

National security review should therefore be integrated into transaction planning, alongside foreign investment market-access analysis, competition law, corporate approvals, and sector-specific licensing.

7.4 Practical implications for investors

Foreign investors should consider national security issues early in the transaction process, particularly where the target company operates in infrastructure, technology, energy, telecommunications, transport, data services, or other strategic sectors.

Due diligence should identify:

• The nature of the target’s business;
• Its principal assets and technologies;
• Its role in critical infrastructure or strategic supply chains;
• The categories of data it processes;
• Its relationships with state institutions;
• Whether it holds licences or approvals relevant to national security;
• Whether the transaction involves access to sensitive information or facilities.

A transaction should not be assessed solely by its financial value or corporate structure. The nature of the business and the potential consequences of foreign control or access may be equally important.

8. Criminal and Administrative Consequences of Violations

8.1 Criminal liability

Serious violations of national security legislation may result in criminal liability under the Criminal Law and other applicable statutes.

The Criminal Law contains offences relating to espionage, stealing, spying into, purchasing, or illegally providing state secrets, and other conduct endangering national security.

The applicable offence depends on the conduct, the information involved, the person’s role, the relevant statutory elements, and the circumstances of the case.

Criminal responsibility is not established merely because a person is foreign, works for an overseas organisation, or has communicated with a foreign institution.

The prosecution must establish the elements of the relevant offence under Chinese criminal law.

8.2 Administrative penalties

Not every breach of national security-related legislation results in criminal prosecution.

Certain violations may lead to administrative penalties, including fines, confiscation of unlawful gains, suspension of activities, revocation of licences, restrictions on operations, or other measures authorised by law.

The applicable consequences depend on the statute governing the conduct.

For example, violations involving foreign NGO registration may be addressed under the Foreign NGOs Law. Data and cybersecurity violations may lead to administrative penalties under the relevant digital legislation. Immigration violations are subject to the Exit and Entry Administration Law.

Foreign companies should not treat administrative enforcement as a minor matter. Regulatory penalties can affect business licences, operations, contractual relationships, reputation, and the ability of personnel to remain in China.

8.3 Corporate and individual responsibility

A company may face regulatory consequences where its activities violate applicable legal obligations. Responsible managers and other individuals may also face personal liability where the law provides for it.

The existence of a corporate compliance department does not automatically protect directors, managers, employees, or contractors from liability for their own conduct.

Companies should therefore establish clear responsibility for data security, confidentiality, licensing, regulatory reporting, and employee training.

8.4 Exit restrictions and travel consequences

Chinese law permits certain restrictions on departure from the country in legally specified circumstances.

The Exit and Entry Administration Law provides for restrictions on the departure of foreigners in particular situations, including where a person is involved in unresolved criminal proceedings, where a court has issued a relevant decision, or where other statutory conditions are met.

Other legislation may also provide for exit restrictions in national security or related investigations.

An exit restriction is not equivalent to a criminal conviction. It may arise during an investigation or legal proceeding, depending on the statutory basis.

Foreign nationals should understand that a dispute involving a company, an investigation, or a regulatory matter may have consequences beyond financial penalties. Where a person becomes subject to a lawful exit restriction, departure from China may not be permitted until the relevant legal conditions are resolved.

9. Investigations and the Powers of State Security Authorities

9.1 The role of state security organs

State security organs are the principal authorities responsible for counter-espionage work under the Counter-Espionage Law.

Their responsibilities include preventing, investigating, and addressing conduct that endangers national security within the scope of the legislation.

They may coordinate with public security organs, departments responsible for state secrets, and other competent authorities.

The Counter-Espionage Law provides statutory powers for investigations, including measures involving persons, premises, documents, electronic equipment, and information where the legal conditions are satisfied.

9.2 Inspection and investigative measures

The law authorises state security organs to take specified investigative measures in accordance with statutory procedures.

Depending on the circumstances, these may include questioning relevant persons, inspecting premises, examining or obtaining relevant documents and electronic data, and taking other measures authorised by law.

The revised law also addresses the inspection of electronic equipment and facilities in counter-espionage investigations.

Such powers are not unlimited. The law establishes procedural requirements and safeguards, and state security organs must act within their legal authority.

Foreign companies should nevertheless understand that electronic records, devices, communications, and documents may become relevant to an investigation where the statutory conditions are met.

9.3 Cooperation with authorities

The Counter-Espionage Law establishes duties of support and cooperation in relevant circumstances. It also imposes confidentiality obligations in relation to state secrets and certain information learned through counter-espionage work.

Foreign organisations should distinguish between a lawful request or compulsory measure and an informal request that requires clarification.

Where a company receives an official demand for documents, access, or assistance, it should verify the authority involved, identify the legal basis and scope of the request, preserve relevant records, and obtain appropriate legal advice.

Employees should not obstruct lawful investigations, destroy potentially relevant material, or disclose protected information to unauthorised persons.

9.4 Rights and safeguards

The Counter-Espionage Law states that counter-espionage work must be conducted according to law and that human rights and the lawful rights and interests of individuals and organisations must be respected and protected.

The law also provides that state security organs and their personnel must not exceed or abuse their powers.

Information obtained during lawful counter-espionage work must be used for the relevant purposes and protected in accordance with the statutory requirements.

Where an individual becomes subject to criminal investigation or compulsory measures, the Criminal Procedure Law becomes relevant. The rights and procedures applicable to criminal suspects, including access to defence counsel and other procedural protections, are addressed in the separate article on police powers, detention, and criminal procedure in China.

The existence of an investigation should not be confused with a finding of guilt. Criminal responsibility is determined through the applicable legal process.

10. Practical Compliance Obligations for Foreign Businesses

10.1 Establish a national security compliance framework

Foreign businesses operating in China should integrate national security considerations into their general compliance systems.

A compliance programme should identify the sectors in which the company operates, the information it collects, the technology it uses, its relationships with public institutions, and the legal restrictions applicable to its activities.

The programme should not rely on generic international policies without adapting them to Chinese law.

10.2 Classify and control information

Companies should identify the categories of information they hold and determine whether any information may constitute personal information, sensitive personal information, important data, trade secrets, work secrets, or state secrets.

Different categories require different controls.

A practical information governance programme should include:

• Access restrictions based on business need;
• Document classification and handling procedures;
• Secure storage and transmission;
• Restrictions on unauthorised copying and disclosure;
• Retention and deletion policies;
• Incident reporting procedures;
• Appropriate employee training.

The classification system should be reviewed regularly, particularly where the company operates in a regulated sector.

10.3 Review cross-border communications

Foreign companies should examine how information moves between Chinese operations and overseas headquarters.

This includes email, cloud storage, enterprise software, video conferencing, remote access, shared databases, internal reporting systems, and external service providers.

The company should determine whether the information includes personal information, important data, state secrets, or other restricted material.

It should also identify whether a lawful cross-border transfer mechanism is required.

A general corporate policy permitting global access to all company records may be inappropriate where Chinese data protection or state-secret rules apply.

10.4 Conduct due diligence on research and consulting providers

Companies frequently use external advisers, research organisations, consultants, auditors, and investigators.

Before engaging such providers, businesses should examine their legal status, methods, information sources, and compliance arrangements.

Contracts should prohibit unlawful information acquisition and unauthorised disclosure. They should also identify responsibilities for data protection, confidentiality, information security, and regulatory cooperation.

A company should not assume that responsibility rests exclusively with the contractor. Depending on the circumstances, the commissioning organisation may also face legal or regulatory consequences.

10.5 Train employees and management

Employees should receive training on:

• State-secret protection;
• Counter-espionage requirements;
• Data security and privacy;
• Restrictions on photography and access to sensitive locations;
• Handling of government and state-owned enterprise information;
• Cross-border data transfers;
• Reporting of suspicious or unlawful requests;
• Cooperation with competent authorities.

Training should be tailored to the employee’s role. An engineer working on telecommunications infrastructure may face different information risks from a sales employee or a human resources manager.

10.6 Preserve records and investigate incidents

Where a company identifies a possible data breach, unauthorised disclosure, or suspicious information request, it should activate its internal incident response procedure.

The organisation should preserve relevant records, restrict further unauthorised access, assess the categories of information involved, and determine whether notification or reporting obligations arise.

It should not destroy documents or alter records in an attempt to avoid regulatory scrutiny.

Where the incident may involve state secrets or national security, the company should obtain specialised legal advice before taking steps that could affect evidence or statutory reporting obligations.

11. Practical Guidance for Foreign Individuals in China

Foreign visitors, students, employees, academics, and businesspeople do not need to treat every ordinary activity as a national security issue. However, awareness of the legal environment can prevent avoidable problems.

11.1 Respect restricted locations

Do not enter military installations, restricted government facilities, or other protected areas without authorisation. Observe posted restrictions and instructions from competent authorities.

Where a location is marked as restricted, do not assume that its apparent accessibility or proximity to a public road authorises entry or photography.

11.2 Be careful with information collection

Avoid attempting to obtain confidential government documents, restricted technical materials, or information that another person is not authorised to disclose.

Do not offer money or other benefits to obtain protected information. Do not encourage employees or officials to breach their confidentiality obligations.

Use legitimate public sources for commercial, academic, and professional research.

11.3 Understand the purpose of research activities

Before conducting surveys, interviews, mapping, technical assessments, or other research, determine whether the activity requires a licence, registration, institutional approval, or other authorisation.

This is especially important for work involving geographic information, infrastructure, strategic industries, government institutions, or large-scale data collection.

11.4 Protect devices and business information

Foreign employees should follow their organisation’s security policies when using laptops, mobile devices, cloud services, and external storage.

They should avoid transferring sensitive business or personal information through unapproved channels and should not assume that information stored in China can always be accessed or transferred overseas without additional requirements.

11.5 Respond carefully to official enquiries

If approached by an authority, an individual should remain respectful, avoid obstructing lawful procedures, and seek to understand the nature and legal basis of the request.

Where the matter is serious, the individual should request appropriate legal assistance and, where relevant, ask about access to consular assistance.

The rules governing criminal investigations and detention are discussed separately in Article 57 of this China section.

12. National Security and International Cooperation

12.1 International business and academic exchange remain lawful

China’s national security legislation operates alongside laws that permit and regulate international trade, investment, research, education, and cultural exchange.

The Foreign Investment Law, company legislation, education regulations, intellectual property laws, and other statutes provide legal channels for foreign participation in the Chinese economy and society.

National security requirements should therefore be understood as part of the regulatory environment rather than as a general prohibition on international cooperation.

12.2 Cooperation with foreign authorities

Cross-border investigations and regulatory cooperation may involve the exchange of documents, evidence, personal information, and other materials.

Chinese law provides mechanisms for international judicial assistance and law enforcement cooperation. However, foreign requests for information or evidence may be subject to approval and procedural requirements.

The Personal Information Protection Law, Data Security Law, state-secret legislation, and other rules may restrict the transfer of information to foreign authorities.

A multinational company should not independently assume that it may disclose information held in China simply because a foreign regulator or court has requested it.

12.3 International treaties and domestic law

China participates in international treaties and cooperation arrangements relevant to criminal justice, cybersecurity, intellectual property, trade, and other areas.

Treaties may provide mechanisms for cooperation, but their application depends on the relevant treaty provisions, China’s domestic legislation, and applicable procedures.

Foreign individuals and organisations should not assume that an international agreement automatically overrides domestic regulatory requirements or provides immunity from Chinese law.

13. Common Misunderstandings About National Security Law in China

Several misconceptions can lead to inaccurate assessments of legal risk.

First, not every foreign activity is treated as espionage. International business, academic research, tourism, and ordinary professional communication are lawful when conducted in compliance with applicable requirements.

Second, state secrets and confidential business information are not identical. A trade secret may be protected under commercial and intellectual property legislation without being a state secret. Conversely, information may be protected as a state secret even where it is not commercially valuable.

Third, information does not have to be visibly marked as classified to raise legal concerns. Its legal status depends on the applicable classification and statutory framework, not merely on whether a document bears a label.

Fourth, foreign nationality does not create immunity. Foreign nationals and foreign organisations must comply with Chinese law when conducting activities within its jurisdiction.

Fifth, ordinary corporate due diligence is not prohibited. However, the methods used to obtain information and the nature of the information itself must comply with the law.

Sixth, compliance with data protection law does not automatically resolve national security issues. Personal information, important data, state secrets, and other protected materials may be governed by overlapping but distinct legal regimes.

Seventh, an investigation is not a conviction. The initiation of an inquiry or the use of investigative powers does not itself establish criminal responsibility.

14. Key Takeaways

• China’s national security framework is based on the Constitution and a network of national security, criminal, administrative, data, cybersecurity, and foreign relations legislation.
• The National Security Law provides a broad framework covering political, economic, technological, social, information, and other security interests.
• The Counter-Espionage Law was substantially revised in April 2023 and entered into force on 1 July 2023.
• The revised Counter-Espionage Law covers specified activities involving state secrets, intelligence, and other materials related to national security or interests.
• The Law on Guarding State Secrets was revised in February 2024 and entered into force on 1 May 2024.
• The implementing regulations for state-secret protection entered into force on 1 September 2024.
• State secrets are classified into top-secret, secret, and confidential categories.
• Work secrets are a separate category and should not automatically be treated as state secrets.
• Foreign nationals and foreign organisations are subject to applicable Chinese national security laws when operating in China.
• Foreign NGOs must comply with the registration or filing requirements under the Foreign NGOs Law.
• The Data Security Law, Personal Information Protection Law, and Cybersecurity Law create important obligations for foreign businesses processing information in China.
• The Cybersecurity Law was amended in October 2025, with the revised provisions taking effect on 1 January 2026.
• The Regulations on Network Data Security Management have been effective since 1 January 2025.
• Cross-border data transfers may require a recognised legal mechanism and cannot be treated as unrestricted internal corporate communications.
• Certain foreign investments are subject to national security review.
• Violations may lead to administrative penalties, criminal prosecution, restrictions on business activities, or other legal consequences.
• Foreign businesses should establish information governance, employee training, due diligence, and incident response procedures.
• Foreign individuals should respect restricted locations, avoid unauthorised information collection, and understand the legal requirements applicable to their professional activities.

15. Frequently Asked Questions

1. Does Chinese national security law apply to foreign nationals?

Yes. Foreign nationals present in mainland China must comply with Chinese law. The Counter-Espionage Law also expressly addresses specified conduct involving overseas institutions, organisations, and individuals. Foreign nationality does not provide general immunity from national security legislation.

2. Is it illegal for a foreigner to collect information in China?

No. Ordinary research, commercial analysis, academic work, and the collection of publicly available information are not automatically unlawful. However, the methods used and the nature of the information matter. Unauthorised acquisition of state secrets, intelligence, or other protected materials may create serious legal consequences.

3. What is the difference between a state secret and a trade secret?

A state secret is information classified under Chinese state-secret legislation because of its importance to state security and national interests. A trade secret is commercially valuable confidential information protected under intellectual property and anti-unfair competition legislation. The categories may overlap in some circumstances, but they are legally distinct.

4. Are all government documents in China state secrets?

No. Not every non-public government document is necessarily a state secret. Some documents may be classified as work secrets or may be subject to other confidentiality and disclosure rules. The legal status depends on the applicable legislation and classification procedures.

5. What are the three levels of state secrets?

The three levels are top secret, secret, and confidential. They reflect different degrees of potential harm to state security and national interests if the information is disclosed.

6. Can a foreign company receive state secrets?

Access to state secrets is restricted and subject to the applicable legal authorisation and confidentiality requirements. A commercial contract or ordinary business relationship does not automatically grant access. Any lawful provision of state secrets in connection with foreign cooperation must follow the prescribed approval procedures.

7. Is academic research in China prohibited for foreign researchers?

No. Foreign researchers may participate in lawful academic and scientific cooperation. However, research involving restricted information, sensitive technologies, regulated geographic data, state secrets, or important data may require additional approvals and safeguards.

8. Can foreign journalists photograph public buildings in China?

Ordinary photography in publicly accessible places is not generally equivalent to espionage. However, restrictions may apply to military facilities, protected locations, restricted infrastructure, and certain government premises. Journalists should observe posted restrictions and avoid unauthorised access or collection of protected information.

9. Are foreign NGOs permitted to operate in China?

Yes, subject to the Foreign NGOs Law and other applicable requirements. Qualifying organisations generally must register a representative office or complete the prescribed filing for temporary activities. They must also comply with statutory restrictions on political, profit-making, and unlawful religious activities.

10. Can foreign companies transfer Chinese business data to their overseas headquarters?

Not without considering the applicable rules. Transfers may be subject to the Data Security Law, Personal Information Protection Law, Cybersecurity Law, and regulations governing network data. Depending on the information and circumstances, a recognised transfer mechanism or other approval may be required.

11. Does China’s national security legislation apply to information stored overseas?

Some Chinese laws have extraterritorial provisions. The Data Security Law and Personal Information Protection Law apply in specified circumstances to activities outside China. The amended Cybersecurity Law also expands its extraterritorial reach in relation to overseas conduct endangering China’s cybersecurity. The precise scope depends on the relevant statute.

12. Can a foreign investor acquire a company in a sensitive Chinese industry?

Potentially, but the transaction may be subject to market-access restrictions, licensing, and national security review. The parties should determine whether the target’s sector, assets, technologies, or infrastructure fall within the applicable review framework.

13. Can Chinese authorities investigate a foreign company?

Yes, where the competent authorities have a lawful basis and act within their statutory powers. Depending on the subject matter, the investigation may involve state security organs, public security authorities, data regulators, market regulators, or other departments.

14. Can a foreign national be prevented from leaving China?

Chinese law provides for departure restrictions in specified circumstances, including certain criminal proceedings and other legally defined situations. An exit restriction is not itself a criminal conviction, but it may prevent a person from leaving until the relevant legal conditions are resolved.

15. Does an investigation automatically mean that a foreign national is guilty?

No. An investigation is a procedural measure, not a determination of guilt. Criminal responsibility must be established through the applicable legal process.

16. What should a foreign business do if it receives a request for sensitive information?

It should identify the authority making the request, verify its legal basis and scope, preserve relevant records, assess the information involved, and obtain appropriate legal advice. It should not obstruct lawful investigations or disclose protected information to unauthorised recipients.

17. Are foreign companies required to train employees on national security matters?

The precise statutory obligations depend on the organisation’s activities and the relevant laws. However, companies with exposure to state-secret protection, data security, counter-espionage, or regulated industries should implement appropriate training and internal safeguards. The Counter-Espionage Law establishes security precaution responsibilities for relevant entities.

18. Does compliance with the Personal Information Protection Law guarantee compliance with national security legislation?

No. Personal information protection and national security are related but distinct legal areas. A transfer that satisfies personal information requirements may still be restricted if it involves state secrets, important data, or other protected materials.

19. Can foreign companies use overseas cloud services in China?

The use of cloud services is not subject to a single universal prohibition. However, the location of data, the nature of the service, the identity of the provider, the categories of information processed, and the applicable cybersecurity and data transfer rules must be considered. Additional requirements may apply to critical information infrastructure operators and organisations processing important data.

20. What is the most important compliance consideration for a foreign organisation operating in China?

The organisation should understand what information it collects, how it obtains that information, where it stores it, who can access it, and whether it may be transferred outside China. It should also assess its sector-specific regulatory obligations, foreign organisation status, investment restrictions, and exposure to national security rules.

16. Principal Legal Sources and Further Reading

The following legislation and official materials provide the principal legal framework for understanding national security, state secrets, counter-espionage, and foreign activities in China.

1. National Security Law of the People’s Republic of China (2015) – establishes the general statutory framework for national security and the responsibilities of state institutions and other entities.
2. Counter-Espionage Law of the People’s Republic of China (revised 2023) – governs counter-espionage activities, defines relevant prohibited conduct, and establishes investigative powers and preventive obligations.
   Read the Counter-Espionage Law
3. Law on Guarding State Secrets of the People’s Republic of China (revised 2024) – regulates the classification, protection, handling, and disclosure of state secrets.
   Read the official government explanation of the 2024 revision
4. Regulations on the Implementation of the Law on Guarding State Secrets (2024) – provide implementing rules for the revised state-secret protection framework.
   Read the State Council announcement
5. Foreign Relations Law of the People’s Republic of China (2023) – establishes the legal framework for China’s foreign relations and addresses the legal position and obligations of foreign nationals and organisations.
   Read the Foreign Relations Law
6. Foreign Non-Governmental Organisations Law (2016) – regulates the registration, filing, activities, and supervision of foreign NGOs operating in mainland China.
   Consult the official Chinese legislative text
7. Data Security Law of the People’s Republic of China (2021) – establishes the data classification, protection, and national security review framework.
   Read the Data Security Law
8. Personal Information Protection Law of the People’s Republic of China (2021) – regulates personal information processing, individual rights, and cross-border transfers.
   Read the Personal Information Protection Law
9. Cybersecurity Law of the People’s Republic of China, as amended in 2025 – the revised law took effect on 1 January 2026.
   Consult the Library of Congress analysis of the amendment and the 2025 amended text in English translation.
10. Regulations on Network Data Security Management (State Council Order No. 790) – effective from 1 January 2025.
    Read the official announcement
11. Measures for the Security Review of Foreign Investment (2021) – establish the national security review procedure for specified foreign investment activities.
12. Law of the People’s Republic of China on the Application of Laws to Foreign-Related Civil Relations (2010) – relevant to certain cross-border private-law questions, although it does not replace national security legislation.

For foreign businesses, the UK Government’s country-specific business risk information also provides a useful overview of practical regulatory issues, particularly data security and cross-border operations: Overseas Business Risk: China.

Conclusion

National security legislation forms an important part of the contemporary Chinese legal system. Its reach extends beyond conventional espionage and military secrecy to include the protection of strategic information, data, infrastructure, technology, economic interests, and other matters regarded as significant to national security.

For foreign individuals and organisations, the central legal challenge is understanding the boundaries between lawful international cooperation and activities that require special authorisation, confidentiality safeguards, or regulatory approval. Commercial research, academic exchange, investment, journalism, and professional services remain possible, but they must be conducted within the applicable legal framework.

The 2023 revision of the Counter-Espionage Law, the 2024 revision of the Law on Guarding State Secrets, the data security regulations effective in 2025, and the amended Cybersecurity Law effective in 2026 demonstrate the continuing development of this framework. They also underline the importance of treating information governance, employee training, regulatory due diligence, and cross-border data management as essential elements of business and institutional compliance.

Foreign organisations should not assume that rules familiar from their home jurisdictions apply unchanged in China. Equally, they should not assume that every foreign activity is prohibited or that ordinary international cooperation constitutes a national security concern. The correct legal assessment depends on the precise activity, the information involved, the applicable statutory provisions, and the procedures governing the relevant sector.

Understanding these distinctions is essential for anyone seeking to work, invest, research, or conduct other professional activities in China.

This article is intended for general legal education and information. It does not constitute legal advice or replace advice from a qualified professional familiar with the relevant Chinese laws and the facts of a particular matter.

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