China’s State Council officially brought Decree No 841—Regulations on Exit-Entry Administration—into force on 15 September 2026. The 19-article measure, published only six weeks earlier, replaces scattered clauses in the Exit-Entry Administration Law, the Passport Law and ancillary regulations with a single rulebook that dramatically expands the grounds on which immigration officials may stop people at the border. Under the decree, authorities may now “dissuade” Chinese citizens from travelling to undefined “high-risk” countries when they apply for passports or reach immigration control. They may also impose exit bans of up to three years on anyone judged to have endangered “industrial or technological security” overseas—a clause experts say could target scientists, engineers and corporate executives working on advanced technology deals. Foreigners face tougher scrutiny as well: those placed on China’s “counter-measures list,” “unreliable entity list” or “malicious entity list” can be refused boarding or physically prevented from departing. Human Rights Watch contends the decree violates the universal right to leave one’s country because many of the new triggers—such as “possible endangerment of national interests”—are so vaguely worded that they invite arbitrary enforcement. Over the past decade China has increasingly used exit bans against rights activists and businesspeople involved in commercial or legal disputes; the new rules, critics argue, codify what had been ad-hoc practice and extend it to a far wider population. For multinational employers the immediate concern is business continuity. Staff based in, or seconded to, China may be unable to travel at short notice if implicated in a pending investigation, export-control review or civil lawsuit. Companies are already revisiting assignment contracts to include evacuation clauses, while risk managers are advising employees to keep personal devices free of sensitive data that could be interpreted as a national-security risk. Practically, travellers should expect longer secondary inspections and additional document checks, especially if their itineraries involve countries that Beijing considers security-sensitive. Legal counsel recommend carrying evidence that the purpose of travel is “truthful and lawful,” the very language used in Article 3, to minimise discretionary delays at passport control.
Source: Human Rights Watch
