China’s 15th Five-Year Plan (十五五): what it promises foreign companies, word by word

China’s 15th Five-Year Plan (2026–2030) promises foreign companies national treatment in full, a shorter negative list and wider access to telecoms, internet and medical services. Most of those openings carry a pace word: in an orderly way, prudently, cautiously. The plan changed no rule, and it ties the next negative list to pilots in named places.

Read from abroad, the plan China adopted in March 2026 sounds like a promise to open wider. It is one. It also says, sentence by sentence, how fast, and those words decide when a foreign company can use any of it. The promises that matter to a foreign company sit in Chapters 21 and 22 of the Chinese text.^⁠[1]

What does the 15th Five-Year Plan promise foreign companies?

Chapter 22 of the 15th Five-Year Plan promises national treatment for foreign-invested enterprises in full (全面落实外资企业国民待遇). It also orders a clear-out of documents and regulations that conflict with the Foreign Investment Law.^⁠[1] It adds that a company admitted to a sector should also be able to get the licences to operate in it (准入又准营).^⁠[1]

Chapter 21 promises a shorter foreign investment negative list, wider market access led by services, and opening of telecoms, the internet, education, culture and medical care.^⁠[1] It also commits China to trial the WTO e-commerce and investment facilitation agreements early, and to make cross-border data flows efficient, convenient and secure.^⁠[1]

None of it is a rule. The outline sets the government’s agenda for five years; it changes no licence, cap or filing. Each promise reaches a company as something else: a new negative list, a ministry notice opening a pilot, or an amended law. Until one of those is published, the texts already in force decide what a foreign company may do.

What do 有序, 稳妥 and 稳慎 mean in the plan?

They are pace words: 有序 means in an orderly way, 稳妥 prudently and 稳慎 steadily and cautiously, and the plan puts them on openings that are still capped or closed. The firmest verbs go to promises the law already makes.^⁠[1]

Word	What the plan attaches it to	Where things stand
Implement in full全面落实	National treatment for foreign-invested enterprises	Already the law: pre-establishment national treatment plus a negative list, since 1 January 2020 (Foreign Investment Law, Article 4)⁠[2]
Reduce缩减	The foreign investment negative list, with no number and no date	The 2024 list, in force since 1 November 2024, has 29 items, down from 31, and none left in manufacturing⁠[3]
In an orderly way有序	Opening telecoms, the internet, education, culture and medical care; opening the digital sector	Most value-added telecom services stay capped at 50% foreign ownership outside the pilot areas⁠[4]
Prudently稳妥	The pilots in value-added telecoms, biotechnology and wholly foreign-owned hospitals	All three pilots opened in 2024, each limited to named places⁠[5,6]
Steadily and cautiously稳慎	Linking China’s financial markets with markets abroad	The plan names two steps: a better qualified foreign investor scheme, and more products it may buy⁠[1]
Trial first率先试行	The WTO e-commerce and investment facilitation agreements	A commitment to apply them early, with no date given⁠[1]
Explore探索	Widening the scope of trademark protection	A direction to study, with no measure named⁠[1]

National treatment in full is a promise to enforce a law in force since 2020, so the gap the plan admits is in local documents and licensing practice, not in the statute.^⁠[1,2] The sector openings are to come through pilots: the plan links each revision of the negative list to them (加强负面清单修订与开放试点联动).^⁠[1]

Which sectors does the plan say will open to foreign companies?

The plan names five sectors to open “in an orderly way”: telecoms, the internet, education, culture and medical care.^⁠[1] For telecoms, internet infrastructure and medical care, a pilot already exists, and the pilot is the door that is open today. For education and culture, the plan names no pilot.

Sector	What is open today	Where
Value-added telecoms增值电信	Up to 50% foreign ownership for most services; no cap for e-commerce, domestic multi-party communications, store-and-forward services and call centres (item 12)⁠[4]	Nationwide
Telecoms pilot	No foreign-share limit for internet data centres, content delivery networks, internet access and online data and transaction processing, among others, with an MIIT pilot approval for each entrant⁠[5]	Approved areas of Beijing, Shanghai (the Lingang New Area and the Pudong leading area), the Hainan Free Trade Port and Shenzhen
Internet content	Closed: internet news, online publishing, online audio-visual services and internet culture, music excepted (item 13), and excluded from the telecoms pilot⁠[4,5]	Nationwide
Biotechnology生物技术	Foreign-invested companies may develop and apply human stem cell and gene diagnosis and therapy technology⁠[6]	The Beijing, Shanghai and Guangdong pilot free trade zones and the Hainan Free Trade Port
Hospitals外商独资医院	Wholly foreign-owned hospitals are to be allowed (拟允许), except traditional Chinese medicine hospitals and not by acquiring a public hospital⁠[6]	Beijing, Tianjin, Shanghai, Nanjing, Suzhou, Fuzhou, Guangzhou, Shenzhen and all of Hainan
Education and culture	No pilot named in the plan⁠[1]	None

Zhejiang is in none of the pilot lists. A pilot’s terms apply in the pilot area, so where the company sits becomes part of the structure. Choosing between a capped structure available nationwide and an uncapped one in a pilot area comes before any licence application, and it is the question our market entry and structure advisory works through.

Will the negative list get shorter, and when?

The 15th Five-Year Plan says the foreign investment negative list will be reduced (缩减), and gives no number and no date.^⁠[1] The list in force is still the 2024 edition: 29 items, in force since 1 November 2024.^⁠[3] Searches of NDRC and MOFCOM on 28 September 2026 found no newer edition. A 2025 list does exist, but it is the market access negative list, which binds domestic and foreign companies alike; our explainer on the two negative lists sets them side by side.

On the plan’s own wording, the sectors to watch are the ones already in pilots. A pilot that works is the plan’s stated route into the next list.^⁠[1]

Can a foreign company sell services into China without a Chinese entity?

Yes, in any field that is not on China’s negative list for cross-border trade in services (跨境服务贸易负面清单), in force since 21 April 2024.^⁠[7] The list has 71 items nationwide and 68 in the pilot free trade zones.^⁠[7] A service supplied from abroad in a field that is not on the list is managed on the same terms as a domestic provider’s.^⁠[7]

The plan promises to improve that list and to relax the limits on services delivered across the border.^⁠[1] Whether your business needs an entity at all starts at do I need a Chinese company to sell in China.

What does national treatment in full change for a company already in China?

In law, nothing new: the Foreign Investment Law has given foreign investment outside the negative list national treatment since 1 January 2020 (Article 4).^⁠[2] What the plan adds is an instruction: clear out the documents and regulations that conflict with that law. It also names a second gap, between being admitted to a sector and being licensed to operate in it (准入又准营).^⁠[1]

The same section keeps review in place. It promises to carry out the foreign investment security review “to a high standard” (高质量实施外商投资安全审查). It also promises to improve how foreign mergers and acquisitions are managed.^⁠[1] Wider access and continued review arrive in the same paragraph.

What has the Five-Year Plan left open?

• Dates and numbers. Neither chapter gives a date, a count or a percentage for any opening.^⁠[1]
• The next negative list. No edition after the 2024 list had been published by 28 September 2026.^⁠[3]
• Education and culture. Both are named for orderly opening, and neither has a pilot.^⁠[1]
• The expo pledge. Premier Li Qiang promised on 24 September 2026 to relax market access further;^⁠[8] no implementing text had followed by 28 September. Our piece on the Global Digital Trade Expo tracks it.

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