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Protect employees traveling or working in China with a plan that starts before booking and covers work authorization, sensitive data, device handling, emergency contacts, and what to do after the trip. Tailor it to the destination, length and purpose of the stay, employee’s nationality and circumstances, and the data they will access. Security measures reduce exposure; they cannot eliminate legal, surveillance, detention, or other risks.
Start with the destination and the traveler’s circumstances
Do not treat mainland China, Hong Kong, and Macau as one jurisdiction or assume that guidance for one applies to the others. The U.S. Department of State’s mainland China advisory, issued September 4, 2026, is Level 2, “Exercise increased caution.” It cites arbitrary enforcement of local laws, exit bans, and risks of unjust arrest or detention. Its page gives Hong Kong and Macau separate guidance; check the current entry and security information for the actual destination.
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The advisory is U.S.-specific. Employees of other nationalities should consult their own government’s current travel advice and understand which consular assistance is available to them. Employers should not present an advisory level as a prediction about an individual employee.
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Factors to assess before approving travel
- Where the employee will go, including whether the itinerary includes mainland China, Hong Kong, or Macau.
- The employee’s nationality, personal circumstances, role, and any relevant business relationships or disputes.
- What work they will perform, how long they will stay, and what devices, accounts, documents, or personal information they will need.
- Whether the assignment involves sensitive, regulated, or strategically important information and who can respond if a concern arises.
The State Department notes that national-security, counterespionage, and data-security laws can give authorities broad discretion. It also describes heightened scrutiny risks for some people, including those involved in business disputes or connected with U.S. corporate entities involved in such disputes. Employees whose circumstances may be relevant should discuss them with their employer and appropriate counsel rather than rely on a generalized risk judgment.
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Build the plan around the trip’s length and work activity
A short visit and a longer assignment raise different practical questions. The Chinese government-hosted 2025 expatriate guide says foreigners working in China should obtain a work permit and describes Z-visa and residence-permit steps. A 2026 edition was published on July 10, 2026, so check that edition and current official Chinese sources for the employee’s specific activity and circumstances. Do not rely on visa-free policy details in the 2025 guide as current: the guide’s stated eligibility language had an end date of December 31, 2025.
| Travel situation | Employer checks |
|---|---|
| Short business trip | Confirm that the entry permission matches the planned activities and stay. The State Department advises travelers to research the visa required for the work they plan to do; do not assume that a meeting or other brief visit is automatically exempt from work-authorization rules. |
| Longer-term work assignment | Confirm the applicable work-permit, entry, and residence requirements through current official Chinese guidance before departure. Assign responsibility for immigration compliance and for tracking any required steps after arrival. |
Local laws apply to business travelers. The 2025 expatriate guide also tells foreign nationals to follow residence-registration provisions, comply with local laws on social media, and not photograph military installations. Check the current guide and official requirements rather than treating this summary as a complete legal checklist.
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Prepare devices and data before departure
Agree on a device and data plan with the employee before travel. The State Department’s general Business Travel and Work Abroad guidance, last updated August 11, 2025, recommends discussing protections with the employer, keeping devices current with security patches and company-approved antivirus or anti-spyware, and not expecting privacy on hotel, airplane, internet-café, or public Wi-Fi. These are general business-travel practices, not a promise that a device or connection is private in China.
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- Decide which devices, accounts, files, and credentials are necessary for the assignment; avoid carrying or exposing information that is not needed for the work.
- Confirm that devices have current security patches and company-approved antivirus or anti-spyware, and that the employee knows how to contact company IT and security support.
- Agree how the employee will access work information and report a lost device, suspicious event, unexpected request, or other security concern.
- Review the itinerary and meeting plans for any company-specific security requirements. The National Counterintelligence and Security Center’s 2024 Companies: Travel Security Guidance addresses planning before travel as well as hotels, meetings, conferences, and social events; apply it in light of relevant law, agreements, and company policy.
During the trip
- Keep electronics, paperwork, and sensitive materials with the traveler, as the State Department advises.
- Do not attach unknown storage devices or peripherals to work equipment. Treat Wi-Fi provided by hotels, airplanes, internet cafés, or public spaces as non-private.
- Use the company’s approved processes for work access and promptly report suspicious approaches or events to the designated company contact. The State Department also advises reporting relevant suspicious events to the FBI; that advice is specific to U.S. travelers and organizations.
These practices reduce avoidable exposure but do not prevent surveillance, access to information, or legal action. Set expectations accordingly, especially for employees who need to handle highly sensitive material.
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Review cross-border employee data handling
Travel does not itself amount to blanket consent for an employer’s cross-border processing of personal information. 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 described statutory exceptions. For sensitive personal information, the FAQ says the individual should also be told why the transfer is necessary and its effects on their rights.
Before employee data moves across borders, ask qualified privacy or legal counsel to assess what information is transferred, the recipient, purpose, scope, applicable legal basis, and transfer mechanism. This is an employer data-compliance issue; it should not be reduced to asking an employee to agree to an itinerary or device policy.
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Give employees an arrival and emergency plan
Give each traveler a written contact sheet before departure, with a company escalation contact, local assistance arrangements, and consular contact details appropriate to the employee’s nationality. Confirm how the employee can reach those contacts if a work account or device is unavailable. The expatriate guide lists these emergency numbers: 110 for assault or property crime, 119 for fire, and 120 for first aid. Confirm local arrangements and how the employee can communicate with responders; do not treat the numbers as a complete medical or safety plan.
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Close the loop after the trip
The State Department advises checking devices before and after travel and changing passwords. Make these actions part of the company’s return process rather than leaving them to memory: ask employees to report device loss, unusual events, or suspected exposure; have IT or security check returned devices under company policy; and follow the company’s password-change and account-review procedures. Preserve information needed for an incident response, and involve appropriate legal or security staff if a concern arose.
Review the plan when destinations, work activities, employee circumstances, or data flows change. Travel advisories, entry rules, and privacy requirements can change as well, so use current official guidance for each trip rather than carrying forward a prior approval unchanged.
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