China Enacts Cross-Border Corruption Law With New Corporate Compliance Duties

China enacted a cross-border corruption law on November 6, 2026, imposing specific compliance obligations on businesses with operations spanning its borders and setting out procedures for international investigations and asset recovery.

The National People's Congress Standing Committee passed the 47-article law on Friday. A presidential order promulgated it the same day, and Article 47 states that it takes effect upon promulgation. The legislation is in force, rather than merely proposed, according to the published statutory text and contemporaneous reporting by China News Service.

The new rules cover Chinese companies investing abroad or operating foreign branches and subsidiaries, as well as branches and subsidiaries established in China by foreign companies. Article 29 defines that scope. Articles 30 to 34 require covered businesses to establish anti-corruption compliance systems, assess risks, strengthen internal reporting, maintain reliable accounting records and conduct due diligence on third-party agents. Chinese companies operating abroad must also make appropriate compliance staffing arrangements in light of their size, activities and risk exposure.

Article 45 provides a graduated enforcement route: authorities may order companies to correct failures to meet compliance obligations, and companies refusing to correct them may face suspension of relevant business, suspension of operations for rectification or revocation of relevant business licences. The law does not say that every compliance lapse automatically triggers a criminal conviction; criminal responsibility under Article 35 depends on whether conduct constitutes an offence under China's criminal law.

The statute also addresses the international dimension. Article 20 permits cooperation with overseas authorities under Chinese law, treaties or reciprocity, including evidence collection and recovery of assets. Article 25 restricts foreign organisations and individuals from conducting anti-corruption investigative or enforcement activity inside China, or obtaining related assistance there, without approval from Chinese authorities. That provision creates a separate legal consideration for multinational compliance investigations and cross-border evidence requests.

The law states that investigators must protect legally covered state, commercial and personal information. It also provides for whistleblower confidentiality and protection under Article 28. These are statutory requirements, not proof of how any particular case will be handled in practice.

The immediate public-interest question is how regulators will apply the new corporate controls, particularly to overseas subsidiaries, agents and information-sharing requests. The published law establishes duties and potential sanctions; it does not itself establish that any named company has violated them. Future enforcement notices, implementing guidance and court rulings will show how these powers are used.