Delta Law Expat Services Desk ｜ Notice on the Integration of the Foreigner's Work Permit with the Social Security Card（《人力资源社会保障部关于做好外国人工作许可证与社会保障卡融合集成工作的通知》）, MOHRSS Doc. No. 75 [2024], integration effective from 2024-12-01
- Since 2024-12-01 a foreign national entering China is no longer issued a physical work permit card. The permit itself did not change; only the way it is evidenced did.
- The legal effect of a work permit comes from the decision granting it, not from a card. Article 39 of the Administrative Licensing Law makes issuing a document conditional — "where a licence document needs to be issued" — rather than constitutive.
- Article 41 of the Exit and Entry Administration Law requires a foreign national to have obtained a work permit and a work-type residence permit. It speaks of obtaining the permit, not of holding a card.
- Verification now runs through the administration system and the electronic social security card at two named points: applying for the residence permit, and social insurance registration.
- Physical cards already issued follow a "no change, no replacement" transition, so two forms of evidence coexist — and three current official texts still call the same permit by different names.
1. The document at a glance
| Item | Content |
|---|---|
| Full title | Notice of the Ministry of Human Resources and Social Security on Integrating the Foreigner's Work Permit with the Social Security Card（《人力资源社会保障部关于做好外国人工作许可证与社会保障卡融合集成工作的通知》） |
| Document number | 人社部发〔2024〕75 号（MOHRSS Doc. No. 75 [2024]） |
| Adopted / promulgated | Dated 2024-10-27; published in State Council Gazette 2025 No. 4 |
| Current version in force from | Integration applies from 2024-12-01 as stated in the Notice; not amended to date |
| Issuing authority | Ministry of Human Resources and Social Security（人力资源社会保障部） |
| Official text | https://www.gov.cn/gongbao/2025/issue_11846/202502/content_7002785.html |
| What this page covers | Where a work permit's legal effect sits once no card is issued, and what an employer is actually evidencing |
2. What changed on 2024-12-01
（一）办理工作许可
工作许可的申请、延期、变更和注销在外国人来华工作管理服务系统（以下简称来华工作系统）全程网上办理，外国人入境后无需再办理实体外国人工作许可证。已领取实体外国人工作许可证的，按照“不变不换”原则，待现有工作许可申请延期或变更时按照证卡融合集成新程序办理。
Section I(1), Handling the work permit: Application for, extension of, change to and cancellation of a work permit are handled entirely online in the Foreigners Working in China Administration and Service System; after entry, a foreign national no longer needs to obtain a physical foreigner's work permit card. Where a physical card has already been obtained, it follows the principle of "no change, no replacement", and the new integrated procedure applies when the existing permit is next extended or varied.
Unofficial translation; the Chinese text as officially published prevails.
Two things are worth separating immediately. The Notice removes a document: after entry, no physical card is issued. It does not remove, suspend or alter the permit — the administrative decision that authorises the person to work. Applications, extensions, variations and cancellations continue; they simply run through the administration system.
The "no change, no replacement" principle means the transition is gradual rather than dated. A card issued before 2024-12-01 is not called in; it is superseded when the underlying permit is next extended or varied. Two years on, a population of foreign staff will typically contain both people who hold a card and people who never had one.
3. Where the legal effect actually sits
Once no card exists, the natural question is what a person "has". The answer is in the general law of administrative licensing, and it was always the answer.
第二条 本法所称行政许可，是指行政机关根据公民、法人或者其他组织的申请，经依法审查，准予其从事特定活动的行为。
第三十九条 行政机关作出准予行政许可的决定，需要颁发行政许可证件的，应当向申请人颁发加盖本行政机关印章的下列行政许可证件：……
Article 2: An administrative licence, for the purposes of this Law, means an act by which an administrative organ, upon application by a citizen, legal person or other organisation and following examination in accordance with law, permits the applicant to engage in a specific activity. Article 39, paragraph 1: Where an administrative organ makes a decision granting an administrative licence and a licence document needs to be issued, it shall issue to the applicant, bearing the organ's seal, one of the following licence documents: …
Unofficial translation; the Chinese text as officially published prevails.
Article 2 defines the licence as the act of permitting — 「准予其从事特定活动的行为」 — not as a certificate. Article 39 then makes issuance conditional: it applies 「需要颁发行政许可证件的」, where a licence document needs to be issued. A card, on this structure, is a means of evidencing a decision that already exists. Removing the card does not remove the decision.
The same logic is visible in the immigration statute, which is the provision an employer is actually judged against.
第四十一条 外国人在中国境内工作，应当按照规定取得工作许可和工作类居留证件。任何单位和个人不得聘用未取得工作许可和工作类居留证件的外国人。
Article 41, paragraph 1: A foreign national working within China shall obtain a work permit and a work-type residence permit as prescribed. No entity or individual may employ a foreign national who has not obtained a work permit and a work-type residence permit.
Unofficial translation; the Chinese text as officially published prevails.
The verb is 「取得」 — to obtain. The statute requires the permit to have been obtained; it does not require a card to be held. That distinction was latent while every permit came with a card, and it is now the operative one.
第四十三条 外国人有下列行为之一的，属于非法就业：
（一）未按照规定取得工作许可和工作类居留证件在中国境内工作的；
（二）超出工作许可限定范围在中国境内工作的；
（三）外国留学生违反勤工助学管理规定，超出规定的岗位范围或者时限在中国境内工作的。
Article 43: A foreign national commits unlawful employment in any of the following: (1) working within China without having obtained a work permit and a work-type residence permit as prescribed; (2) working within China beyond the scope limited by the work permit; (3) a foreign student working within China beyond the prescribed range of posts or time limits, in breach of the rules on work-study.
Unofficial translation; the Chinese text as officially published prevails.
Item (2) deserves particular notice in a paperless setting. The limits of the permit — employer, post, period — are part of the permit, and they are now held in the system rather than printed on a card in the person's wallet. An arrangement that drifts beyond those limits is caught by item (2) whether or not anyone is holding a card. The three layers of consequence for the employer are examined separately (see Further reading).
4. How the permit is verified now, and at which points
（四）办理居留证件
外国人持Z字签证入境后，持《外国人工作许可通知》或加载工作许可信息的电子社保卡前往工作地公安出入境部门办理有关居留证件，有关部门可通过信息系统直接核验，也可通过查看电子社保卡、扫描工作许可二维码等方式查询、获取外国人的工作许可信息。
Section I(4), Handling the residence permit: After entering on a Z visa, the foreign national goes to the public security exit and entry authority at the place of work, with the Notification of Foreigner's Work Permit or an electronic social security card carrying the work permit information, to handle the relevant residence permit; the relevant authorities may verify directly through the information system, and may also query and obtain the foreign national's work permit information by viewing the electronic social security card or scanning the work permit QR code.
Unofficial translation; the Chinese text as officially published prevails.
Section II(1) of the same Notice places a parallel verification step at social insurance registration: the social insurance handling body 「应当通过来华工作系统对外国人工作许可信息进行验证」 — it verifies the work permit information through the administration system. Two features follow. First, the primary source of truth is the system record, with the electronic card and its QR code as access points to the same record. Second, verification is performed by the receiving authority rather than presented by the applicant, which changes what a party is expected to produce.
| Stage | Who verifies | Against what | Source |
|---|---|---|---|
| Work permit application, extension, variation, cancellation | Handled online in the administration system | The system record | Notice, s. I(1) |
| Residence permit | Public security exit and entry authority at the place of work | Direct system verification; alternatively the electronic social security card or the permit QR code | Notice, s. I(4) |
| Social insurance registration | Social insurance handling body | Verification of the work permit information through the administration system | Notice, s. II(1) |
Everything beyond this allocation — what an authority asks for on a given day, what format it accepts, how a query is made — is subject to the current published requirements of the accepting authority, and this page does not restate any such requirement.
5. One permit, three official names
Integration did not synchronise the vocabulary of the texts that surround it.
二、将第二条修改为“在中国境内就业的外国人，是指依法获得《中华人民共和国外国人工作许可证》、《外国常驻记者证》等就业证件和外国人居留证件，以及持有外国人永久居留证件，在中国境内合法就业的非中国国籍的人员。”
Item 2: Article 2 is amended to read: "A foreign national employed within China means a person of non-Chinese nationality who has lawfully obtained employment documents such as the Work Permit for Foreigners in the People's Republic of China or the Foreign Resident Correspondent Certificate together with a foreigner's residence permit, or who holds a foreigner's permanent residence document, and who is lawfully employed within China."
Unofficial translation; the Chinese text as officially published prevails.
That is the 2024 name. The rules that actually govern employment of foreign nationals were last revised in 2017 and were not touched by either the 2024 order or the integration notice, so they continue to use the older name — for the same permit.
第八条 在中国就业的外国人应持Z字签证入境（有互免签证协议的，按协议办理），入境后取得《外国人就业证》（以下简称就业证）和外国人居留证件，方可在中国境内就业。
Article 8: A foreign national employed in China shall enter on a Z visa (or as provided by an applicable mutual visa exemption agreement) and, after entry, obtain a Foreigner's Employment Certificate (the "employment certificate") and a foreigner's residence permit before working within China.
Unofficial translation; the Chinese text as officially published prevails.
6. What an employer is actually evidencing
The shift from card to record changes the object of proof. Where a file previously contained a copy of a card, the underlying question was always whether a valid permit existed for this person, this employer, this post and this period. That remains the question; only the source of the answer has moved into the administration system and the electronic social security card that reads from it.
Three consequences follow from the texts, and no further. First, a physical card retained under "no change, no replacement" proves what it says as at issue, and the permit may since have been extended or varied — so a card alone is not a statement of the current position. Second, the permit's limits, being system-held, are as capable of being checked by an authority as the permit's existence, which makes Article 43(2) of the Exit and Entry Administration Law a live test throughout the employment rather than only at onboarding. Third, no currently published text states how an employer should record permit status for its own evidential purposes; the position on that is per the officially published text, and this page does not invent one.
What can be said with confidence is what the employer is answerable for. Article 41 asks whether the permit and the work-type residence permit were obtained; Article 43 asks whether the work stayed within the permit. Neither asks whether a card was in a drawer.
7. Who runs into this, and how it is used
The people who meet this most often are employers whose foreign staff population spans the transition, HR teams building or revising onboarding checks, and individuals whose physical card has lapsed on a variation and who are asked for a document that no longer exists. In each case the analysis begins by separating the permit from the way it is shown.
- Misconception: With no card issued, the permit requirement has been relaxed. In fact: Article 41 of the Exit and Entry Administration Law is unchanged and requires the permit and the work-type residence permit to have been obtained; the Notice changes only how the permit is evidenced.
- Misconception: A physical card still held shows the current position. In fact: cards continue under "no change, no replacement" and are superseded at the next extension or variation, so a card states the position as at issue and no later.
- Misconception: Because the permit information sits on a social security card, it is a social insurance matter. In fact: the work permit is an administrative licence in its own right; the card carries the information and is the access point, while social insurance registration is one of the points at which the information is verified.
- Misconception: The different names used in current documents indicate different permits. In fact: three current texts use different names for the same permit; this page reproduces each under its own name and no inference should be drawn from the difference.
- Check whether a permit has in fact been obtained, and on what terms — employer, post and period — rather than whether a card can be produced; Article 41 and Article 43(1) of the Exit and Entry Administration Law are framed on obtaining the permit.
- Assess ongoing compliance against Article 43(2), since the scope limits of a permit are system-held and a change of role, entity or location may take the work outside the permit without any document changing hands.
- Identify which staff still hold a physical card and when their permits were last extended or varied, given that "no change, no replacement" means a card and a system record can state different things.
- Quote each surrounding text under its own name in employment documents and internal policies — the Rules, the amended Social Insurance Measures and MOHRSS Doc. No. 75 [2024] use three different names for the same permit.
- Treat the evidential question as open: no currently published text prescribes how an employer should record permit status, so any internal practice should be assessed on its own terms rather than presented as a prescribed requirement.
- Laws and Regulations index
- Work & Invest · Employment Rights and Starting a Business
- Arrive · Visas, Work Permits & Permanent Residence
- Employing a Foreign National Without a Work Permit: Three Layers of Legal Consequence for the Employer
- Social Insurance for Foreign Employees in China: Mandatory Participation, Bilateral Treaty Exemptions, and What Order No. 54 Changed in December 2024
- 《人力资源社会保障部关于做好外国人工作许可证与社会保障卡融合集成工作的通知》，人社部发〔2024〕75 号，2024 年 10 月 27 日，自 2024 年 12 月 1 日起实施证卡融合集成。本文引用其一（一）、一（四）、二（一）、三（二）。官方原文（国务院公报 2025 年第 4 号）https://www.gov.cn/gongbao/2025/issue_11846/202502/content_7002785.html
- 《中华人民共和国行政许可法》，2003 年 8 月 27 日通过，根据 2019 年 4 月 23 日《关于修改〈中华人民共和国建筑法〉等八部法律的决定》修正。本文引用其第二条、第三十九条第一款。官方原文 http://www.npc.gov.cn/c2/c30834/201906/t20190608_298033.html
- 《中华人民共和国出境入境管理法》，主席令第五十七号，2013 年 7 月 1 日施行，全文 93 条，至今未修正。本文引用其第四十一条第一款、第四十三条。
- 《人力资源社会保障部关于修改〈在中国境内就业的外国人参加社会保险暂行办法〉的决定》，人社部令第 54 号，2024 年 12 月 23 日公布并自公布之日起施行。本文引用其决定第二项。官方原文（国务院公报 2025 年第 2 号）https://www.gov.cn/gongbao/2025/issue_11806/202501/content_6999379.html
- 《外国人在中国就业管理规定》，劳部发〔1996〕29 号，现行为 2017 年人力资源和社会保障部令第 32 号修订版，全文 36 条。本文引用其第八条。
- Status and timing note 效力与时点提示：MOHRSS Doc. No. 75 [2024] is dated 2024-10-27 and applies the integration from 2024-12-01; it has not been amended as at the verification date of this page. No officially published text of the interface specifications referred to in section III(2) has been located as at 2026-09-05, and no currently published text prescribes how permit status is to be recorded by an employer for evidential purposes. Decisions on the work permit and on the residence permit rest with the competent authorities named in the texts above; all procedural matters are subject to the current published requirements of the accepting authority.
This article is general legal research and does not constitute legal advice; by law, a law firm may not guarantee case outcomes. 本文为一般性法律研究，不构成法律意见；依据法律规定，律所不得承诺办案结果。
