China enforces salary thresholds (6x/4x local avg wage) for work permits. Employers face rising costs; strategies include annual adjustments or downgrading to Category B with police clearance.
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Facing New Salary Benchmarks for Foreigner’s Work Permits in China? Here’s How Employers Can Respond
Fuki Fu
Manager, HR & Payroll Services, Shanghai Office
Key takeaway:
Facing rising compliance pressure from new foreigner’s work permit salary benchmarks in China? With stricter enforcement and annually adjusted wage thresholds, employers are confronted with higher costs and renewal risks for retaining their foreign employees. This article breaks down what’s changed and outlines practical strategies for employers to stay compliant while controlling workforce expenses.
面对中国新版外国人工作许可薪资基准带来的日益加大的合规压力？随着监管趋严以及薪资门槛的逐年调整，用人单位在留任外籍员工时正面临成本上升与续签风险加剧的双重挑战。本文将为您深度剖析政策变化，并梳理出实用策略，助力企业在控制用工成本的同时确保合规。
As outlined in our previous article, regulatory enforcement for foreigner’s work permits in China has tightened markedly since early February 2026. While salary‑based entry thresholds for Category A and Category B talent have long existed in policy, enforcement in major cities such as Beijing and Shanghai had been relatively flexible in recent years, particularly during the pandemic period. This approach has now clearly shifted.
Multiple immigration and global mobility alerts issued in early February 2026 confirm that China is fully re‑implementing salary‑based qualification pathways for Category A and Category B Foreigners’ Work Permits. Local authorities have begun verifying salary information directly within the national work permit management system, signaling a move toward consistent and centralized enforcement.
In parallel, local governments have updated the payroll commitment template. Unlike the previous version, which specified fixed salary amounts, the revised template links compensation thresholds to six times or four times the average annual wage of employees in urban units in the relevant region for the previous year.
As a result, foreign nationals applying in cities that were previously more permissive may face significantly higher minimum compensation requirements, affecting both new applications and renewals. This approach also means that salary benchmarks will now adjust annually in line with the release of updated wage data. In Shanghai, for example, average wage figures are typically announced in mid‑July, with revised thresholds applying from July 1 of the current year through June 30 of the following year. For foreign employees qualifying through the salary‑based pathway, this introduces a requirement to reassess and adjust their annual salary.
For employers, these changes present new compliance and workforce-planning challenges, particularly for companies that employ or plan to hire foreign talent. Below are several strategies enterprises may consider in response.
Strategy 1: Annual salary adjustment in line with average wage growth
The most straightforward approach is to adjust the salaries of foreign employees each year to meet the new standards set by the local average wage increase. This method ensures continuous compliance with the salary requirements for Category A or B Work Permits, minimizing the administrative burden of changing application categories or preparing additional materials.
However, this strategy comes with a notable drawback: it leads to a steady increase in labor costs for enterprises. As the local average wage rises year by year, the financial burden on companies will grow incrementally. For businesses operating on tight budgets or in industries with thin profit margins, this may not be a sustainable long-term solution.
Strategy 2: Downgrading from Category A to Category B
For enterprises struggling to bear the rising costs of maintaining Category A status for their foreign employees, downgrading to Category B is a viable alternative.
Here are three common approaches to this transition:
Approach 1: Adjusting salary to meet Category B salary thresholds
Enterprises may lower the applicable salary benchmark from six times the local average wage (Category A threshold) to four times the local average wage (Category B threshold) by reclassifying the applicant. This adjustment can significantly reduce overall salary costs and help ease the enterprise’s financial burden.
However, companies should note that a Category A to Category B downgrade triggers additional documentary requirements. In particular, the applicant must submit a police clearance certificate issued by the relevant authorities in their country (or countries) of residence. The certificate must confirm that the applicant has no criminal record and typically needs to be valid, up to date, and, where required, properly notarized and legalized. This additional requirement reflects the stricter compliance standards applied to Category B applications and should be factored into both timeline planning and document preparation when pursuing this adjustment.
Approach 2: Reapplying under traditional Category B criteria
Another option is to reapply for the Foreigners’ Work Permit under the traditional Category B qualification criteria – foreign professional talents holding a bachelor’s degree or higher and possessing no less than two years of relevant work experience.
In practice, many of these candidates were able to apply under Category A at the time of their initial employment precisely because Category A does not require prior work experience. Instead, Category A eligibility can be met through alternative pathways, most notably salary benchmarks (for example, meeting the six‑times‑average‑wage threshold), academic qualifications, or other qualifying indicators. This made Category A an attractive and efficient option for candidates who were early‑career professionals or recent graduates and therefore unable to satisfy Category B’s experience requirement at that time.
With the recent tightening of enforcement around salary‑based Category A pathways, some of these employees may no longer meet the updated salary benchmarks or be too expensive to do so. In such cases, reapplying under traditional Category B criteria becomes a practical alternative, particularly where the employee has since accumulated sufficient work experience.
To proceed under the traditional Category B route, the applicant must submit the following key supplementary documents:
Authenticated bachelor’s degree certificate: The applicant must obtain official authentication for their bachelor’s degree, which may involve notarization and legalization, depending on the country of issuance.
Authenticated police clearance certificate: Similar to the first approach, a valid police clearance certificate is mandatory to confirm the applicant’s clean criminal record.
Proof of relevant work experience: Applicants are required to demonstrate at least two years of work experience related to their current position. However, for employees who have been with the same enterprise for more than two years, this requirement may be waived, as their in-house work experience can be recognized in place of external proof.
For employers, this transition requires careful assessment of documentation readiness and timelines, but it may offer a viable compliance pathway where salary‑based Category A thresholds are no longer sustainable.
Approach 3: Applying through the Category B points-based assessment
In addition to the salary benchmark pathway and the two-year work experience pathway, the points-based assessment system for Category B Work Permits offers a more flexible pathway, focusing on multiple aspects of the applicant’s profile rather than just salary. To qualify, applicants must score at least 60 points, with points awarded based on the following criteria:
Age: Younger applicants receive higher points, with maximum points typically awarded to those under 45 years old.
Salary: Even though the salary threshold is lower than Category A, a higher salary still contributes to a higher score.
Educational background: Higher levels of education, such as master’s or doctoral degrees, earn more points.
Length of work in China: Longer periods of continuous work in the country add to the total score.
Chinese language proficiency: Proficiency in Chinese, demonstrated through standardized tests or practical application, can significantly boost the applicant’s score.
This approach is ideal for foreign employees who may not meet the strict salary requirements but possess strong qualifications in other areas, such as advanced education, language skills, or extensive professional experience in China.
Key takeaway
China’s updated salary requirements for Foreigners’ Work Permits call for proactive and strategic responses from employers. Whether enterprises choose to adjust salaries annually, reclassify work permit categories, or pursue alternative application pathways, careful consideration must be given to both cost implications and the individual qualifications of foreign employees.
Effective compliance will depend on forward planning, a clear understanding of the available options, and timely adjustments to compensation and documentation strategies. By assessing these factors early, businesses can remain compliant with evolving regulations while mitigating operational disruption and financial pressure.
Given the increasing complexity and stricter enforcement of work permit requirements, enterprises are also advised to consult professional immigration or HR service providers. Expert guidance can help navigate procedural changes, manage timelines, and support well‑informed, business‑specific decisions in an increasingly regulated environment.
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