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Protect employees by planning for the specific destination, work activity, employee profile, and data involved—not by relying on a single “China” checklist. Before travel, employers should confirm current entry and work requirements, assess security and privacy exposure, agree on device and data controls, and give employees a clear escalation plan. Keep that plan active during the trip and include a device and incident review after return.
Start with the destination and the employee’s circumstances
Mainland China, Hong Kong, and Macau should not be treated as one security jurisdiction. The U.S. Department of State’s China Travel Advisory, issued September 4, 2026, rates mainland China Level 2, “Exercise increased caution,” citing arbitrary enforcement of local laws, exit-ban use, and risks of unjust arrest or detention. The advisory discusses Hong Kong and Macau separately; employers should read the guidance for the actual destination rather than applying the mainland rating to all three.
This is U.S. government guidance, not a prediction about what will happen to a particular traveler or a substitute for advice from the traveler’s own government. Ask employees to check their nationality’s current travel advice and consider relevant personal circumstances with their employer and appropriate counsel. The State Department identifies business disputes and connections with U.S. corporate entities involved in such disputes among circumstances that may draw heightened scrutiny; communicate this as a factor in its advisory, not as a certainty about any individual.
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- Short business visit: Confirm that the planned work activity and length of stay fit current entry and work rules, and limit access to information and systems to what the visit requires.
- Longer assignment: Verify the work-permit, visa, residence, and registration requirements for the assignment before departure, and establish who will support the employee locally.
- Sensitive work: If the employee will handle regulated, strategically important, or otherwise sensitive information, have security and privacy specialists assess the trip and approve a narrower access plan.
The State Department says national-security, counterespionage, and data-security laws can give authorities broad discretion and describes risks that may affect routine business and research activity. Employers should explain the official warning clearly, without implying that device precautions can eliminate legal, detention, or surveillance risks.
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Confirm work authorization and local obligations before booking
Do not assume that a business-visitor entry permission covers the work an employee will actually perform. The Chinese government-hosted 2025 expatriate guide says foreigners working in China should obtain a work permit and describes Z-visa procedures for work of up to 90 days and for longer stays, including a work-related residence-permit step after arrival for longer work. A government notice confirms publication of a 2026 edition on July 10, 2026, but the current procedural detail and eligibility rules should be checked in that edition and against official Chinese sources before travel.
- Write down the employee’s actual duties, work location, and expected length of stay; have qualified immigration support determine which requirements apply.
- Confirm who obtains each permit or visa, what must be completed before entry, and what must be completed after arrival. Do not use old visa-free eligibility language as current: the 2025 guide’s cited visa-free policy had an end date of December 31, 2025.
- Include residence registration and other local requirements in the employee’s arrival plan. The 2025 guide instructs foreign nationals to follow residence-registration provisions and local laws on social media, and not to photograph military installations.
- Recheck rules shortly before departure. Do not treat a prior employee’s experience or an older guide as confirmation that the current rules are unchanged.
Decide what information can travel and cross borders
Before departure, the employer should map the work information the employee will access, store, create, or transfer, and identify who will receive it. Avoid giving a traveler routine access to data or systems that are not needed for the assignment. This is both a security decision and, where personal information is involved, a privacy-compliance question.
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China’s Cyberspace Administration (CAC), in a policy FAQ dated July 24, 2026, says that when personal information is provided outside China, the processor is to notify the individual and obtain separate consent under the cited Personal Information Protection Law provisions, subject to the stated statutory exceptions. For sensitive personal information, the FAQ says the individual should also be told why the cross-border transfer is necessary and the effects on their rights. Employee travel by itself should not be treated as blanket consent.
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- Ask privacy or legal counsel to identify the personal information involved, where it is held, who receives it, the purpose and scope of any transfer, the applicable legal basis, and any required transfer mechanism.
- Set an approved method for accessing or sharing work files and define which systems or records are off-limits during the trip.
- Tell employees how to handle unexpected requests for information and whom to contact before disclosing or transferring data outside the approved plan.
Prepare devices and employees before departure
The U.S. State Department’s general Business Travel and Work Abroad guidance, last updated August 11, 2025, recommends discussing device and data protection with the employer before travel. These are general business-travel practices, not China-specific guarantees.
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- Agree on a travel-device plan. Decide with the employee and security team which company-managed devices and accounts are needed. Apply current security patches and company-approved antivirus or anti-spyware before departure.
- Reduce what is carried. Keep electronics, paperwork, and sensitive materials controlled by the traveler. Carry only the work material required for the trip and follow company rules for storage and access.
- Set network expectations. Do not expect privacy on hotel, airplane, internet-café, or public Wi-Fi. Use only company-approved access methods and avoid using an untrusted network for sensitive activity when a safer approved option is available.
- Reject unknown peripherals. Do not attach unfamiliar storage devices or other unknown peripherals to a work device.
- Agree on reporting and recovery. Give the employee a named company security contact and instructions for reporting a lost device, suspicious approach, unexpected access prompt, or other security concern. Make sure the employee knows how to reach support if a company account or device needs to be secured.
Company policy should also cover meetings, hotels, conferences, and social events. The National Counterintelligence and Security Center’s 2024 Companies: Travel Security Guidance is designed to help companies develop overseas travel-security policy and addresses those settings. Apply it in the context of relevant laws, regulations, agreements, and company policy.
Give employees a usable arrival and emergency plan
Before the employee leaves, provide a short plan they can access without relying on a single device or network. Include the local employer contact, company security escalation route, accommodation and transport arrangements, and nationality-appropriate consular contact details. Confirm how the employee can get local-language assistance where needed.
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The 2025 Chinese expatriate guide lists 110 for assault or property crime, 119 for fire, and 120 for first aid. Employers should verify local arrangements for the employee’s actual location and make clear how to contact the company and the appropriate consular service as well. The guide says a lost passport should be reported immediately to a local police station.
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- Agree when the employee should report a concern to the employer, security team, or relevant authorities, and who will coordinate next steps.
- For U.S.-incorporated organizations, the State Department points companies to the Overseas Security Advisory Council (OSAC) for security updates.
Maintain support during the trip and close out on return
Keep a reliable check-in channel open, especially for longer assignments or trips with elevated risks. The employer should know how to reach the employee and who is responsible for responding to a missed check-in or reported incident. If circumstances change—such as a work dispute, a change in duties, or a new request to access sensitive information—pause and reassess the approved plan with the right security, legal, or privacy contacts.
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After travel, follow the company’s established process to check devices and accounts, change passwords where appropriate, and report suspicious events to the company security team. The State Department recommends checking devices before and after travel and changing passwords; it also advises reporting suspicious approaches or events to the FBI and company security team where relevant. These steps can help identify and respond to concerns, but they do not establish that a device or account is free of risk.
For repeat travel or assignments involving sensitive work, review what worked, update the company’s travel-security policy, and verify current official guidance before the next departure. Entry rules, advisories, and privacy requirements can change.
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