China Compliance Update – Summer 2025

Anti-corruption has remained an area of focus area for Chinese authorities in the first half of 2025, with major legislative updates and enforcement cases.

Legislative Updates

On June 27, 2025 the revised Anti-Unfair Competition Law (AUCL) was published, which will take effect on October 15, 2025.

The AUCL is China’s major law regulating commercial bribery and was last revised in 2019. The main changes in the 2025 AUCL relating to commercial bribery are:

• Emphasis on investigating and punishing both the payment of bribes and the acceptance of bribes. The 2019 AUCL did not explicitly prohibit accepting bribes and did not explicitly list administrative penalties for companies or individuals which accepted bribes, even though such conduct was, in practice, frequently the focus of enforcement actions. The 2025 AUCL fills this gap, bringing it in line with recent years’ enforcement trends in China.
• More severe punishments. The 2025 AUCL raises the upper limit for fines for commercial bribery from RMB 3 million (approximately $423,000) to RMB 5 million (approximately $704,000).
• Individual liability. The 2019 AUCL did not provide administrative penalties for individuals if their company was found to have engaged in commercial bribery. Under the 2025 AUCL, legal representatives, senior managers, or other employees directly responsible for paying bribes, or the individuals who accept bribes, will be subject to fines up to RMB 1 million (approximately $141,000).

The revised AUCL also introduces a “long-arm jurisdiction” clause in Article 40, providing that violations of the AUCL which take place outside of China but which have impact within China may be investigated and punished in accordance with the AUCL. At present, however, there is no practical guidance on how this provision will be implemented.

There have been important updates in anti-corruption regulation of the healthcare sector as well. On January 14, 2025, the Compliance Guidelines for Healthcare Companies to Prevent Commercial Bribery Risks (医药企业防范商业贿赂风险合规指引) was published. These guidelines compile the mainstream interpretation of China’s anti-corruption regulatory framework, similar to the Foreign Corrupt Practices Act Resource Guide published by the U.S. Department of Justice and the U.S. Securities and Exchange Commission.

On May 20, 2025, the National Healthcare Security Administration (NHSA, 国家医疗保障局) published the Notice on Further Refining the Drug Pricing and Procurement Credit Evaluation System (2025 Credit Evaluation, 国家医疗保障局办公室关于进一步完善医药价格和招采信用评价制度的通知). This notice provides more severe penalties for companies paying bribes to public healthcare professionals, including the potential to be debarred from public procurement nationwide.

Enforcement Cases

In March and April 2025, the Supreme People’s Procuratorate, the Supreme People’s Court, and the Central Commission for Discipline Inspection of the Communist Party of China (CCDI, 中共中央纪律检查委员会 中华人民共和国国家监察委员会), a government agency responsible for anti-corruption investigations of government officials, published statistics on their anti-corruption enforcement activities in 2024 and 2025.

• In 2024, 5,081 individuals were prosecuted for corruption-related crimes in the finance, energy, healthcare, and infrastructure sectors. Of these, 3,068 individuals were prosecuted for paying bribes, an increase of 18.3% compared with 2023.
• In 2024, 30,000 cases of corruption, bribery, and other crimes relating to the abuse of authority by both government officials and private employees and involving 33,000 individuals were concluded, an increase of 22.3% from 2023. Also in 2024, 8,474 cases relating to the crime of accepting bribes by private employees or the crime of embezzlement and implicating 10,873 individuals were concluded, a 25% increase from 2023. In addition, 2,473 cases relating to the crime of paying bribes and implicating 2,873 individuals were concluded, an increase of 18.6% over 2023.
• In the first quarter of 2025, the CCDI initiated 220,000 investigations into government officials who potentially accepted bribes. In addition, 7,027 individuals were investigated for providing bribes to government officials, and 954 were criminally prosecuted.

In the healthcare sector, two former officials of the National Medical Products Administration (NMPA, 国家药品监督管理局) were investigated by the CCDI for “serious violations of discipline and law” in the first half of 2025, although as is customary, no further details of the investigations were disclosed.

© Arnold & Porter Kaye Scholer LLP 2025 All Rights Reserved. This Advisory is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.