🇨🇳China

Detailed overview

China at a glance

China (population approximately 1.41 billion — figure not separately primary-verified) is the world's second-largest economy with a managed-float renminbi, capital and foreign-exchange controls (administered by SAFE), and a pro-CBDC, anti-private-crypto policy framework. Hong Kong and Macao are Special Administrative Regions with their own currencies, regulators and laws (a VATP/stablecoin regime in Hong Kong; Macao casinos): nothing in this guide applies to either SAR. Mainland regulation across crypto, payments and gambling is consolidated in central authorities (PBoC, NFRA, CSRC, SAFE; Ministry of Finance for lotteries; Ministry of Public Security and Cyberspace Administration for enforcement).

Crypto regime — comprehensive prohibition:

• 15 September 2021 Notice — PBoC + 9 agencies' Notice on Further Preventing and Handling the Risk of Speculation in Virtual Currency Transactions: all crypto-related business is an "illegal financial activity"; financial institutions and non-bank payment institutions barred from providing services
• Reaffirmation (28 November 2025) — PBoC coordination meeting with 13 agencies (incl. Ministry of Public Security, Cyberspace Administration, Supreme People's Court) restated the ban; stablecoins flagged as ML/illegal-fund-transfer risk; offshore exchanges remain off-limits
• Mining — prohibited from 2021 (NDRC); enforcement continues (Sichuan/Butuo County local notice, February 2026); previously >50% of global hashrate, now driven offshore
• Stablecoins/offshore tokens — offshore companies prohibited from issuing tokens tied to Chinese domestic assets or the yuan without explicit authority approval
• Tax/standing — crypto is not legal tender; civil contracts touching crypto generally unenforceable; "illegal-gains" confiscation; criminal exposure under the Criminal Law for organising/facilitating illegal financial activities, illegal fundraising, fraud, MLM and money-laundering offences
• e-CNY — sole legal digital currency; pilots since 2019; December 2025 PBoC policy permits interest on verified wallets and treats e-CNY balances under deposit insurance; cross-border pilots (Singapore, UAE, Hong Kong, Thailand, Saudi Arabia); e-CNY International Operation Center launched in Shanghai (September 2025)

Payments and e-money regime (PBoC):

• Regulation on Supervision and Administration of Non-Bank Payment Institutions — State Council; published 17 December 2023; in force 1 May 2024; first administrative regulation in the field; replaced the 2010 PBoC Administrative Measures on Payment Services Provided by Non-financial Institutions
• Implementation Rules — PBoC draft (22 April 2024); two categories — stored-value account operation and payment transaction processing (replacing the previous internet payment / bank-card acquiring / prepaid-card three-category split)
• Capital/long-term licensing: minimum registered capital RMB 100 million (≈ USD 14.7m); long-term licences replaced the five-year renewal cycle from 2024 (13 first-batch long-term licences issued July 2025 — incl. Douyin Pay, Petal Pay)
• Foreign-invested payment institutions — PBoC Announcement No. 7 of 2018; cross-border servicing of Chinese users requires a domestic licensed entity
• Customer reserve funds — Depository Measures for Clients' Provisions of Non-bank Payment Institutions (January 2021); 100% reserve ratio for e-CNY reserve funds at non-bank PIs
• Market size — 169–186 active licensed payment institutions (down from 271 issued since 2011); Alipay and WeChat Pay dominate; the PBoC sandbox supports fintech innovation pilots; foreign-financial-institutions cross-border restrictions remain
• Currency: CNY, managed-float; PBoC daily midpoint; 2% trading band; onshore CNY vs offshore CNH; capital controls

Gambling regime — Criminal Code prohibition + state-monopoly lotteries:

• Article 303 of the Criminal Law of the PRC (as amended 2020) — all gambling prohibited; up to seven years' imprisonment for organisers; fines reported up to RMB 500,000; lottery winnings taxed at 20%
• State monopolies: China Welfare Lottery (Ministry of Civil Affairs roots, 1987) and China Sports Lottery (General Administration of Sport, 1994) — both Ministry-of-Finance-supervised; only legal lottery/sports-betting products
• Online (non-lottery) gambling — illegal; Announcement 105 of August 2018 prohibits unauthorised online lotteries; Cyberspace Administration enforces site-blocking; offshore-targeting Chinese citizens illegal incl. abroad (Criminal Law Article 7)
• Advertising: Article 9(8) of the Advertising Law prohibits marketing of gambling services/products; only state-run lottery advertising permitted within the Regulations on Lottery Management
• Enforcement (2024): 4,500+ illegal online gambling sites dismantled, 11,000+ individuals arrested (Ministry of Public Security)
• Minimum participation age: 18 (lottery); credit-based sales prohibited
• SAR exclusion: Macao (Macao Gaming Inspection and Coordination Bureau — DICJ) and Hong Kong (HKJC monopoly) are excluded from mainland prohibition under separate SAR systems

Last verified: May 2026. Reference rate: USD 1 = CNY 6.80 (1 CNY ≈ USD 0.147). The renminbi is a managed-float with a PBoC daily midpoint and 2% trading band; the offshore CNH typically trades within a few cents of the onshore CNY.

China is a hard-prohibition jurisdiction for crypto (PBoC + multi-agency 2021/2025 notices) and private gambling (Criminal Law Article 303; state-lottery monopolies only); the only positive licensing path is non-bank payments under the 1 May 2024 Regulation, with e-CNY as the sole legal digital currency.

Is there a crypto licence in China?

No. China prohibits all virtual-currency business as an "illegal financial activity" under the PBoC + nine-agency Notice of 15 September 2021, reaffirmed at the 28 November 2025 PBoC inter-agency meeting. The only legal digital currency is the e-CNY (digital yuan); offshore exchanges may not serve Chinese residents and stablecoins are flagged as money-laundering risk.

The legal foundation:

• 15 September 2021 Notice (PBoC + 9 agencies) — all crypto business is an "illegal financial activity"; financial institutions and non-bank payment institutions barred from servicing crypto
• 28 November 2025 PBoC coordination meeting (13 agencies) — reaffirmation; enforcement priorities; stablecoin ML risk flagged
• Mining prohibition (NDRC, 2021; local enforcement continuing — Sichuan/Butuo County, Feb 2026)
• Criminal Law — illegal financial activity, illegal fundraising, fraud, MLM, ML offences applicable; Article 7 reaches Chinese citizens abroad
• Offshore tokens — offshore issuers may not tie tokens to Chinese domestic assets or the yuan without authority approval

Structure:

• No positive VASP/exchange/custody/issuer/mining authorisation exists; banks/PIs may not service crypto
• Tokenised securities and corporate "blockchain" pilots run within state-controlled rails (Shanghai SASAC stablecoin/blockchain discussions noted as potential pilot direction)
• The only legal digital currency is the e-CNY, via PBoC-designated participants, not a private licence

Operational reality:

• A genuine, actively-enforced absolute ban on private crypto — not a viable jurisdiction for any licensed crypto activity
• Targeting Chinese users from offshore is legally and operationally hazardous (criminal liability for domestic staff/partners, ISP blocking, Cyberspace Administration enforcement)
• Independent counsel and rigorous sanctions/AML screening required; verify status directly with the PBoC/NFRA before any planning

Payments & E-money (People's Bank of China)

Best for payment institutions prepared to license federally with the PBoC under the 2024 Non-Bank Payment Institutions Regulation, with a domestic Chinese entity and substantial registered capital.

What it is: PBoC licence as a Non-Bank Payment Institution under the Regulation on Supervision and Administration of Non-Bank Payment Institutions (in force 1 May 2024) in one of two categories — stored-value account operation or payment transaction processing.

Who it suits: Domestic payment-service providers, big-tech payment arms (Alipay, WeChat Pay model), prepaid-card issuers, merchant-acquiring/aggregating businesses, e-commerce-platform payment subsidiaries; foreign-invested entities subject to PBoC Announcement No. 7 of 2018 approval.

Covers: Stored-value account operation (e-wallets, prepaid accounts) and payment transaction processing (online payment, bank-card acquiring, code-based payment); not banking deposit-taking, not securities, not cross-border services to mainland users without a domestic licensed entity.

Operational requirement: Chinese legal entity; PBoC licensing (long-term, since 2024) with minimum RMB 100 million registered capital; customer-reserve-fund custody at the PBoC (100% reserve ratio); AML/CFT under the Anti-Money Laundering Law; data-localisation under the Cybersecurity Law/PIPL/DSL; foreign-invested entities subject to PBoC Announcement No. 7 of 2018; KYC/KYB controls; e-CNY participation per PBoC programme rules.

Headline figures

• Primary instrument: Regulation on Supervision and Administration of Non-Bank Payment Institutions (State Council, 17 Dec 2023; in force 1 May 2024); PBoC Implementation Rules (draft April 2024)
• Regulator: PBoC (payments licensing); NFRA (banking/non-securities); SAFE (FX/cross-border); CSRC (securities)
• Minimum capital: RMB 100m (≈ USD 14.7m); long-term licences (no 5-year renewal) from 2024
• Market: 169–186 active licensed payment institutions; 13 long-term licences (Jul 2025); 271 licences issued historically
• e-CNY: sole legal digital currency; pilots since 2019; December 2025 interest policy; cross-border pilots (HK/SG/UAE/TH/SA); 100% reserve ratio for e-CNY at non-bank PIs
• Currency: CNY managed-float; PBoC daily midpoint; 2% band; CNH offshore

Is there a gambling licence in China?

No private licence. All gambling is criminally prohibited under Article 303 of the Criminal Law (as amended 2020); only the China Welfare Lottery (1987) and China Sports Lottery (1994) — Ministry-of-Finance-supervised state monopolies — are permitted. Online gambling is prohibited; offshore-targeting Chinese citizens is criminal (Article 7 of the Criminal Law). Macao and Hong Kong operate under separate SAR systems and are excluded.

The legal foundation:

• Article 303 of the Criminal Law of the PRC (as amended 2020) — all gambling prohibited; up to 7 years' imprisonment for organisers; fines reported up to RMB 500,000; underground casinos targeted
• Announcement 105 of August 2018 — unauthorised online lotteries prohibited
• Article 9(8) of the Advertising Law — gambling advertising prohibited (except state lotteries within Regulations on Lottery Management)
• Criminal Law Article 7 — extraterritorial reach to Chinese citizens gambling abroad; gambling-tourism organisers also criminal
• Regulations on Lottery Management — Ministry-of-Finance-led framework for the two state lotteries (CWL + CSL)

Structure:

• Welfare Lottery / Sports Lottery: state monopolies; not licensable to private operators; lottery winnings taxed at 20%
• Casinos / sportsbooks / online gambling: illegal; criminal exposure for operators, organisers, facilitators, advertisers and (for organising) players
• Macao/Hong Kong (SARs): separate jurisdictions — Macao Gaming Inspection and Coordination Bureau (DICJ) for casinos (Law No. 7/2024 credit-lending restrictions; Law No. 20/2024 increased penalties for illegal gambling); HKJC monopoly in Hong Kong — outside the scope of this mainland guide
• Online enforcement — Cyberspace Administration site-blocking; Ministry of Public Security 2024: 4,500+ illegal sites dismantled, 11,000+ arrests; 2021 ~100,000+ arrests

Gambling — not available (criminally prohibited; state-monopoly lotteries only)

Not applicable — there is no private gambling licence in mainland China and none can be issued; the only legal products are the China Welfare Lottery and the China Sports Lottery (state monopolies under the Ministry of Finance).

What it is: There is no private gambling authorisation in mainland China; all private gambling (incl. online) is a criminal offence.

Who it suits: No private operator — market entry is not legally possible for private casinos, sportsbooks, online gambling, poker or private lotteries.

Covers: Nothing for private operators; only the state Welfare Lottery and Sports Lottery (Ministry-of-Finance-supervised) are permitted.

Operational requirement: Not applicable; organising, participating in, facilitating, advertising or providing technical/payment services to gambling exposes individuals and operators to imprisonment and fines under Article 303 of the Criminal Law and related offences; Chinese citizens are reachable abroad under Article 7.

Headline figures

• Status: comprehensively prohibited (Criminal Law Article 303; Announcement 105 of Aug 2018; Advertising Law Art. 9(8))
• State-monopoly lotteries: China Welfare Lottery (1987); China Sports Lottery (1994); Ministry-of-Finance-supervised
• Penalty (organisers): up to 7 years' imprisonment; fines reported up to RMB 500,000 (≈ USD 73,500)
• Tax on legal lottery winnings: 20%
• Enforcement (2024): 4,500+ illegal sites dismantled; 11,000+ arrests (MPS)
• SAR exclusion: Macao and Hong Kong (separate jurisdictions; not covered here)

Costs and timelines at a glance

• Crypto: comprehensively prohibited (PBoC + 9-agency Notice of 15 Sept 2021; reaffirmed 28 Nov 2025 13-agency meeting); illegal financial activity; mining banned (2021 NDRC); offshore tokens tied to PRC assets/yuan need authority approval; only e-CNY is legal; criminal exposure under the Criminal Law
• Payments primary instrument: Regulation on Supervision and Administration of Non-Bank Payment Institutions (State Council, 17 Dec 2023; in force 1 May 2024); two categories (stored-value account operation; payment transaction processing); min capital RMB 100m (≈ USD 14.7m); long-term licences from 2024 (13 long-term licences Jul 2025)
• Payments regulators: PBoC (payments); NFRA (banking); SAFE (FX); CSRC (securities); foreign-invested PIs need PBoC approval (Announcement No. 7 of 2018)
• e-CNY: sole legal digital currency; cross-border pilots (HK/SG/UAE/TH/SA); 100% reserve at non-bank PIs
• Gambling: comprehensively prohibited (Criminal Law Art. 303; Announcement 105/2018); state monopolies only — CWL + CSL (Ministry of Finance); up to 7 years + fines up to RMB 500k; 20% lottery-winnings tax; Macao/Hong Kong SARs excluded
• Currency: CNY managed-float; PBoC daily midpoint; 2% trading band
• FX: USD 1 = CNY 6.80 (1 CNY ≈ USD 0.147)

Who China suits and who it does not

Suitable for

• Domestic non-bank payment institutions and big-tech payment arms able to license with the PBoC under the 2024 Regulation, meet the RMB 100m capital threshold and operate within the long-term licensing model
• Banks and large financial groups operating in mainland China under PBoC/NFRA supervision (foreign banks now without prior equity-cap/JV constraints per the 2024 Negative List)
• Foreign-invested payment institutions willing to establish a domestic licensed entity and undergo PBoC Announcement No. 7 of 2018 approval to serve mainland users
• PBoC-designated banks and selected non-bank PIs participating in the e-CNY (digital yuan) programme, incl. cross-border pilots with HK/SG/UAE/TH/SA

Not suitable for

• Any private crypto/VASP business — comprehensively prohibited; offshore servicing of mainland users is criminally hazardous, with domestic staff/partners liable
• Stablecoin or token issuers tying offerings to PRC domestic assets or the yuan without explicit authority approval — prohibited
• Any private gambling, sportsbook, online-casino, poker or private-lottery operator — criminally prohibited under Article 303; offshore targeting unsafe under extraterritorial reach (Article 7); Macao/Hong Kong are separate jurisdictions
• Foreign financial institutions seeking to operate cross-border into mainland China without a domestic licensed entity — not permitted
• Businesses sensitive to capital and FX controls, data-localisation/PIPL/DSL/Cybersecurity Law requirements, or strict AML/sanctions and enforcement risk (incl. Ministry of Public Security and Cyberspace Administration enforcement)