The new law and State Council regulations don’t specifically require a criminal background check. In fact, while the draft State Council regulations required submission of a “certificate of no criminal conviction” at the visa application stage (art. 8), that was dropped in the final regulations (art. 7). Still, agencies have the power to create rules requiring a criminal background check. For example, the Beijing Municipal Bureau of Human Resources and Social Security has announced that employment license applicants will need to submit a “certificate of no criminal conviction” (also known as a police clearance letter) from their country of residence, effective July 1. Beijing joins other cities, such as Suzhou and Nanjing, which already have similar requirements in place.

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