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This guide explains key points about government relations and lobbying in Chengdu, China, in plain language. In China the term "lobbying" is not always used the same way as in some Western systems. Activities aimed at influencing public policy, government decisions, procurement, permits or local incentives are typically handled as "government relations" or "government affairs." Those activities are subject to a mix of national laws, administrative regulations, Party discipline and local rules. Chengdu, as the capital of Sichuan Province and a major commercial center, has its own administrative practices and public procurement platforms that businesses and individuals must navigate carefully.
Important practical realities are that direct payments, gifts or benefits to public officials are strictly prohibited and can lead to criminal liability. Communications with officials must follow formal channels where required, such as public hearings, procurement platforms, or written submissions. Many interactions are lawful if they are transparent, documented and comply with applicable laws and local procedures.
Engaging a lawyer experienced in government relations and administrative law in Chengdu can be important in many situations. Common reasons to seek legal help include:
- Planning or negotiating public-private partnerships (PPP), municipal infrastructure projects or land use matters where multiple permits and regulatory approvals are required.
- Participating in government procurement, bidding or tendering processes that have strict procedural rules, compliance requirements and tight timelines.
- Seeking tax incentives, subsidies, special approvals or policy-based support from municipal or provincial authorities, and needing help with application documents and follow-up.
- Managing relationships with local government agencies during business expansion, licensing, approvals for environmental permits, health and safety permits or foreign investment filings.
- Conducting due diligence and compliance checks on local agents, consultants or intermediaries to avoid criminal or administrative risk associated with bribery or improper facilitation payments.
- Responding to administrative penalties, inspections, audits or official investigations by supervisory or discipline authorities.
- Structuring corporate or non-profit activities where the Foreign NGO Management Law, charity regulation or registration requirements apply.
- Drafting clear engagement agreements, confidentiality undertakings and compliance clauses for consultants, lobbyists or local partners.
- Defending against allegations of commercial bribery, corruption or other unlawful conduct that could result in criminal charges, administrative sanctions or reputational harm.
Key legal and regulatory themes to understand when dealing with government relations and lobbying in Chengdu include the following:
- National framework and absence of a single "lobbying law" - China does not have a single comprehensive statute labeled "lobbying law" like some other jurisdictions. Instead, activities are governed by a combination of national laws, administrative regulations, departmental rules and Party discipline, all of which affect how you may interact with officials.
- Anti-bribery and criminal liability - The Criminal Law criminalizes bribery of state functionaries and commercial bribery. Giving money, gifts, benefits or other improper advantages to public officials or using intermediaries to provide benefits can lead to severe penalties, including imprisonment and fines.
- Anti-unfair competition and commercial bribery - The Anti-Unfair Competition Law and related administrative rules prohibit commercial bribery and unfair competitive conduct aimed at winning business or preferential treatment.
- Government procurement and bidding rules - The Government Procurement Law and local procurement platforms impose detailed procedures, disclosure requirements and anti-collusion rules for public tenders and government purchases. Chengdu uses public resources trading centers and online platforms for many procurement activities.
- Party discipline and supervision - The Chinese Communist Party and national supervisory organs enforce rules on officials' conduct and interactions with outside parties. Investigations and administrative discipline can be swift and broad in scope.
- Foreign NGO and overseas entity rules - Foreign NGOs and overseas entities operating or doing "political" or public policy related work in China are regulated by the Overseas NGO Management Law and related rules. Registration, a local sponsoring body and clear scope of activities are often required.
- Public-private partnership and project approval regimes - PPP projects and major municipal investments have specialized approval and tender rules, requiring legal and financial structuring and compliance with local procurement and supervisory requirements.
- Data protection, confidentiality and state secrets - Certain information is protected under state secrecy rules or data protection regulations. Communications that involve sensitive information require careful handling and legal review.
- Local administrative measures - Chengdu and Sichuan provincial authorities may issue local measures, procurement thresholds, licensing procedures and guidance that supplement national rules. Local government organs such as the Chengdu Municipal Commerce Bureau, the public resources trading center and industrial park management committees implement and enforce practical requirements.
- Practical compliance steps - Common compliance expectations include written engagement agreements with consultants, documented meeting records, transparent expense reporting, anti-bribery policies, internal training, and thorough due diligence on local partners and intermediaries.
Lobbying-style activities are not illegal per se. However, influencing government decisions must be done within legal and ethical boundaries. Direct or indirect bribery, improper benefits to officials, or secret payments are prohibited and can result in criminal or administrative sanctions. Lawful approaches include public submissions, participation in formal consultation processes, use of registered agents or consultants, and transparent applications through official channels.
China does not have a nationwide mandatory lobbyist registration system like some other jurisdictions. Certain activities by foreign NGOs or overseas entities may require registration or a local sponsor under the Overseas NGO Management Law. In addition, some industries and local platforms have registration or qualification requirements for consultants. Always check whether specific local rules or contract terms require registration or qualification.
Yes, foreign companies regularly engage with Chengdu authorities for investment, permitting, procurement and incentives. Foreign entities should observe rules on foreign NGO activities if their work is public-policy related, ensure compliance with foreign-investment reporting, and avoid any behavior that could be construed as bribery. Using reputable local counsel and transparent processes is recommended.
Bribery can include cash payments, gifts, hospitality or any benefit offered to influence an official act. It also includes providing benefits to relatives of officials or engaging intermediaries to funnel advantages. The form of the benefit does not matter - what matters is the intent and the effect. Transparent, documented, lawful interactions are less risky than secret payments or undue advantages.
Use written contracts that clearly define scope, deliverables and fees. Require compliance representations and anti-bribery clauses, conduct thorough background checks, verify qualifications and references, and set clear payment terms tied to legitimate services. Avoid contingency fees tied to obtaining approvals that could incentivize improper conduct.
If you are subject to an administrative or criminal inquiry, engage qualified local counsel immediately. Preserve documents and communications, halt any questionable conduct, and follow legal advice on interaction with investigators. Early legal involvement helps protect rights, manage disclosures and coordinate responses with regulators.
Gifts, entertainment and hospitality involving public officials are highly sensitive and often prohibited. Some minimal, routine courtesy items may be allowed in business contexts, but because rules and enforcement are strict, it is safer to avoid offering gifts or paid entertainment to public officials. If in doubt consult counsel and follow internal policies that prohibit such practices.
Government procurement typically proceeds through public announcements on the public resources trading platform, with formal bid documents, qualification requirements and evaluation criteria. Review procurement notices carefully, prepare compliant bid documentation, and observe anti-collusion rules. Legal counsel can assist with bid preparation, pre-qualification and bid protests.
Key elements include an anti-bribery policy, due diligence procedures for third parties, written engagement templates, approval controls for interactions with officials, training for staff, incident reporting channels, and periodic audits. Tailor the program to local risks and keep records of interactions and approvals.
Look for lawyers or firms with experience in administrative law, anti-corruption, public procurement, PPPs and local government relations. Ask about specific Chengdu or Sichuan experience, past matters of the same type, language capabilities, and a clear fee structure. Initial consultations help assess fit and practical approach.
- Chengdu Municipal People’s Government - for official notices, policy announcements and contact points for municipal departments.
- Chengdu Public Resources Trading Center - the municipal platform for public procurement and tender announcements.
- Sichuan Provincial Department of Commerce - for provincial-level investment guidance, incentives and trade matters.
- State Administration for Market Regulation and local market supervision bureaus - for rules on commercial conduct and anti-unfair competition enforcement.
- National Supervisory Commission and local supervisory commissions - for information on anti-corruption enforcement and related procedures.
- Ministry of Public Security and local public security bureaus - for matters that may involve criminal investigation or public security concerns.
- Sichuan Lawyers Association and local bar associations - to locate qualified legal practitioners with local experience.
- Industry and foreign chambers of commerce - such as local branches of international chambers - for practical guidance, networking and shared experience on government relations in Chengdu.
- Key national laws and regulations to consult - Criminal Law, Anti-Unfair Competition Law, Government Procurement Law, Overseas NGO Management Law, PPP guidelines and administrative licensing rules.
- Clarify your objectives - document what you want to achieve, the authorities involved and any deadlines or project milestones.
- Gather relevant documents - contracts, permits, correspondence, corporate records and any prior submissions to authorities.
- Conduct a quick risk assessment - identify potential legal, regulatory and reputational risks, especially those involving interactions with public officials.
- Consult qualified local counsel - choose a lawyer with Chengdu or Sichuan experience in government relations, procurement, administrative law and compliance.
- Ask for a written engagement letter - ensure scope, fees, confidentiality and deliverables are set out clearly.
- Follow a compliance-first approach - adopt or update policies for third-party engagements, document all meetings and communications, and avoid gifts or payments that could be misconstrued.
- Prepare for formal procedures - if you are dealing with procurement or approvals, follow published application processes, meet documentation requirements and keep timelines.
- If under investigation - stop any questionable conduct, preserve evidence, and let counsel handle communications with authorities.
This guide is for informational purposes only and does not constitute legal advice. For a tailored assessment and representation you should contact a qualified lawyer in Chengdu who can review your specific facts and recommend concrete steps.
