China Anti-Corruption: 2025 Year in Review

Anti-corruption remained a key area of focus for Chinese regulators in 2025. This Advisory summarizes key legislative developments and major enforcement trends from the past year. 

Revised Supervision Law

On June 1, the revised Supervision Law (中华人民共和国监察法) came into effect. The Supervision Law codifies the structure and authority of supervisory commissions, which are government agencies that regulate the conduct of individuals who carry out public duties in China, such as government officials, and the leadership and managers of state-owned enterprises (SOEs). Individuals who do not perform public duties, but who pay or facilitate the payment of bribes to individuals who do, might also be subject to supervisory commission investigations. The revised Supervision Law provides additional measures that may be taken by the supervisory commissions, such as restricting individuals’ movement for up to 24 hours to ensure their participation in an investigation. The revised law also emphasizes the protection of enterprises’ property rights and management autonomy during the investigation process.

Revised Anti-Unfair Competition Law

On June 27, China’s National People’s Congress (NPC) published the revised Anti-Unfair Competition Law (AUCL, 中华人民共和国反不正当竞争法), which took effect on October 15. The AUCL is China’s major administrative law regulating commercial bribery, enforced by the Administration for Market Regulation. Key revisions include an emphasis on punishments for both the payor and payee, higher maximum fines, and an expanded scope of individual liability for the personnel of entities found to pay bribes.¹

Anti-Corruption Enforcement

Statistics released by Chinese authorities also reflected regulators’ continued commitment to anti-corruption enforcement:

• Data from the Central Commission for Discipline Inspection of the Communist Party of China (CCDI) shows that in 2025, commissions for discipline inspection nationwide initiated 1,012,000 investigations into government officials for corruption-related issues. These investigations implicated government officials at all levels, from top-tier leadership to local officials.²
• Data from the Supreme People’s Procuratorate (SPP) shows that from January to November 2025, 2,982 individuals nationwide were prosecuted for providing bribes, representing a year-on-year increase of 7.6%. The data also reflected regulators’ continued emphasis on punishing both those who provide and accept bribes, as evidenced by revisions to the AUCL and other laws and regulations. 

In December 2025, the National Audit Office published the Report on the Remediation of Issues Identified in the Audit of Central Budget Execution and Other Fiscal Revenues and Expenditures for Fiscal Year 2024 (Audit Report, 2024年度中央预算执行和其他财政收支审计查出问题整改情况的报告), which listed audit findings from the National Audit Office and corresponding remediation measures. The Audit Report noted that more than 430 cases of severe violations of the Communist Party of China’s disciplinary regulations and other laws identified during the audit have been transferred to relevant authorities for further investigation and prosecution. These cases involved corruption and bribery in key areas, including finance, management of state-owned property, and matters relating to public welfare, such as China’s state-run medical insurance program and healthcare system. 

The audit findings and remediation measures listed in the Audit Report are also aligned with the priorities shown in the model enforcement cases published by regulators. For example:

• In July 2025, the Ministry of Public Security (MPC) published five model criminal cases of internal corporate corruption. When publishing these cases, the MPC also encouraged private companies to strengthen their internal anti-corruption controls, such as internal audits, and to establish effective governance mechanisms.
• In November 2025, the Supreme People’s Court (SPC) and the SPP published six model cases of criminal corruption in the finance sector, such as bribery and embezzlement cases implicating government officials from financial regulators and state-owned banks.
• In December 2025, the SPC and the SPP published five model cases of criminal corruption relating to public welfare in the areas of housing security, elder care services, China’s state-run medical insurance program, school meals, and the protection of people with disabilities. ³

We expect anti-corruption to remain a focus in 2026. On January 14, 2026, the CCDI released the Announcement of the Fifth Plenary Session of the 20th Central Commission for Discipline Inspection of the Communist Party of China (Announcement, 中国共产党第二十届中央纪律检查委员会第五次全体会议公报). The Announcement listed key areas for anti-corruption enforcement in 2026, including but not limited to SOEs, industry and academic associations, financial institutions, and public tenders.

For questions on this or any other subject, please reach out to the authors or any of their colleagues in Arnold & Porter’s White Collar Defense & Investigations practice group.

*Zhewen Zhang contributed to this Advisory.

© Arnold & Porter Kaye Scholer LLP 2026 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.