Published by ChinaMNC · Qianfeng

Navigating China's Government Information Disclosure System: A Guide for Foreign Founders

A practical overview of China's government information disclosure framework, including key regulations and planning documents, for foreign entrepreneurs establishing or operating a business in China.

Understanding Government Information Disclosure in China

For foreign founders setting up or running a company in China, access to official government information is essential for compliance and strategic planning. The Chinese government operates a structured information disclosure system, governed by the Regulations on Open Government Information of the People's Republic of China (effective April 15, 2019). This framework requires government agencies to proactively publish certain information and to respond to requests from the public, including foreign investors.

Key Regulations and Notices

The State Council General Office and its Government Information and Openness Office have issued several notices and interpretations that shape how information disclosure works in practice. These include:

• Measures for the Management of Information Processing Fees (December 1, 2020) – outlines when fees may apply for processing information disclosure requests.
• Notice on the Format of Annual Reports on Government Information Disclosure (September 29, 2021) – standardizes how agencies report their disclosure activities.
• Notice on Regulating Government Information Disclosure Platforms (December 3, 2019) – provides guidance on the operation of official disclosure portals.
• Interpretations on Handling Information Disclosure Applications after Institutional Reforms (February 11, 2019) – clarifies which agency is responsible after government restructuring.
• Interpretations on Channels for Receiving Information Disclosure Applications (October 24, 2017) – explains how requests can be submitted.
• Interpretations on the Subject of Replies to Information Disclosure Applications (October 24, 2017) – identifies which authority must respond.
• Interpretations on Filing Annual Reports (October 24, 2017) – details reporting requirements.
• Interpretations on Delivery of Information Disclosure Decisions (October 24, 2017) – covers how decisions are communicated.
• Interpretations on Distinguishing Information Disclosure from Business Inquiry Matters (October 24, 2017) – helps users understand the scope of the disclosure system.

Additionally, the Notice on the Measures for the Formulation of Information Disclosure Rules for Public Enterprises and Institutions (December 21, 2020) and the Guiding Opinions on Several Issues Concerning the Trial of Administrative Reconsideration Cases on Government Information Disclosure (January 4, 2022) provide further context for how disclosure obligations are implemented and reviewed.

National Development Plans

The government publishes national economic and social development plans that can inform business strategy. These include the Outline of the 15th Five-Year Plan (2026–2030), the 14th Five-Year Plan and 2035 Vision, and earlier plans dating back to the 10th Five-Year Plan. These documents outline priorities in areas such as innovation, infrastructure, and social development.

Sector-specific plans are also available, such as:

• Special Education Development and Enhancement Action Plan (15th Five-Year Plan) – approved by the State Council.
• Intellectual Property Protection and Utilization Plan (15th Five-Year Plan) – issued by the State Council.
• National Fitness Plan (2026–2030) – issued by the State Council.
• Plan for Expanding Consumption (15th Five-Year Plan) – approved by the State Council.
• National Health Plan (15th Five-Year Plan) – issued by the State Council.
• Plan for the Revitalization and Development of Traditional Chinese Medicine (15th Five-Year Plan) – approved by the State Council.

Foreign founders can review these plans to identify sectors with government support and potential regulatory changes.

Annual Reports on Government Information Disclosure

Each year, government agencies at various levels publish annual reports on their information disclosure work. The platform provides access to reports from:

• Provincial-level governments (e.g., Beijing, Tianjin, Hebei, Shanxi, Inner Mongolia, Liaoning, Jilin, Heilongjiang, Shanghai, Jiangsu, Zhejiang, Anhui, Fujian, Jiangxi, Shandong, Henan, Hubei, Hunan, Guangdong, Guangxi, Hainan, Chongqing, Sichuan, Guizhou, Yunnan, Tibet, Shaanxi, Gansu, Qinghai, Ningxia, Xinjiang).
• Vertically managed systems such as the People's Bank of China, Customs, Taxation, Financial Supervision, Securities Regulatory, Meteorological, Grain and Strategic Reserves, Tobacco, Railway, Civil Aviation, Postal, Mining Safety, Fire Rescue, and Foreign Exchange systems.
• State Council departments including the Ministry of Foreign Affairs, National Development and Reform Commission, Ministry of Education, Ministry of Science and Technology, Ministry of Industry and Information Technology, and many others.

These reports are available for years 2020 through 2025 (with some earlier years as well) and can provide insight into how agencies handle disclosure requests and what information is publicly available.

Practical Steps for Foreign Founders

To make use of China's government information disclosure system, foreign founders should:

1. Identify the relevant agency – Determine which government body oversees the industry or issue you are interested in.
2. Check proactive disclosures – Many agencies publish information on their websites without requiring a formal request.
3. Submit an information disclosure request – If needed, follow the procedures outlined in the regulations and interpretations, using the proper channels.
4. Review annual reports – These reports can help you understand what types of information are typically disclosed and how requests are processed.
5. Consult national and local plans – Use these documents to align your business strategy with government priorities.

While the system is designed to be accessible, language barriers and procedural nuances may require the assistance of local legal counsel or consultants familiar with Chinese administrative processes.

This summary is based on information published by the relevant Chinese government website and is general information, not legal or tax advice.