China has taken manufacturing restrictions on foreign investment to zero. The next wave of opening is pointed somewhere else — at services. But it is arriving the way China now does most liberalisation: through city-by-city, sector-by-sector pilots, not a single nationwide switch. For a foreign investor, the useful question is not "is China opening?" but "which service opening is real for my sector and my city — and what still sits underneath it?"
- The current nationwide foreign-investment negative list is the 2024 edition — 29 items (effective 1 November 2024), with manufacturing restrictions already at zero. The frontier has moved to services.
- The 15th Five-Year Plan (2026–2030) names services as the next opening — telecom and the internet, healthcare, education and culture — and calls for pilots in value-added telecom, biotechnology and wholly foreign-owned hospitals.
- Two concrete pilots are already live: wholly foreign-owned hospitals in nine cities and areas (from late 2024), and wholly foreign-owned value-added telecom (VATS) in four (Beijing, Shanghai, Shenzhen, Hainan).
- A "pilot" is geography-bound and licence-bound. Lifting an ownership cap does not waive the operating licence, the security review, or the data regime beneath it.
- Read the plan as a direction of travel, not an enacted right. Confirm the current list and the pilot rules for your city before you commit capital.
For most of the last decade the story of foreign access to China was written in manufacturing. That chapter is essentially finished: the 2024 nationwide negative list cut restrictions on foreign investment in manufacturing to zero. What remains restricted — and therefore where the next round of opening has to happen — is services. This is the through-line of the 15th Five-Year Plan, and it is already showing up in specific pilot programmes. Here is what is signal, what is already law, and what still sits underneath the headline.
1. Manufacturing is open; services is the new frontier
The operative instrument for market access is the foreign-investment negative list: sectors on the list are restricted or prohibited for foreign investors; everything off it is, in principle, open on the same terms as for domestic companies. The current nationwide edition is the 2024 version, with 29 items, in force since 1 November 2024 — and it took manufacturing restrictions to zero. Because the manufacturing side is done, the political and regulatory energy has shifted to the part of the list that is still long: services.
2. What the 15th Five-Year Plan actually says
China's 15th Five-Year Plan (2026–2030) makes "opening up" one of its themes, and it makes services the main arena. The plan and its accompanying signals point at a cluster of long-protected service industries — telecommunications and the internet, healthcare, education and culture — and call for pilot opening-up programmes in fields including value-added telecom services, biotechnology and wholly foreign-owned hospitals, alongside a further shortening of the negative lists and a refreshed catalogue of encouraged industries.
Two cautions on how to read this. First, a five-year plan is a statement of direction, not a self-executing law — the openings it describes take effect only when a negative list, a ministry measure, or a pilot notice actually issues. Second, the pattern is selective and controlled: China is opening chosen services, in chosen places, to eligible applicants — not throwing the whole sector open at once.
3. Healthcare: wholly foreign-owned hospitals
The clearest example of the services pivot is healthcare. In September 2024 China issued a pilot policy allowing wholly foreign-owned hospitals, and in November 2024 the National Health Commission and three other departments published the detailed work plan. It permits wholly foreign-owned hospitals in nine cities and areas — Beijing, Tianjin, Shanghai, Nanjing, Suzhou, Fuzhou, Guangzhou and Shenzhen, plus the whole of Hainan island.
The change is real: previously a foreign investor in a hospital generally had to take a Chinese partner holding at least a 30% stake. Full foreign ownership in these locations removes that constraint. But it is still a pilot confined to named places, and a hospital remains one of the most heavily licensed businesses there is — the ownership opening sits on top of, not instead of, the health-sector approvals.
4. Value-added telecom: the VATS pilot
The second live example is telecom. In late 2024 the Ministry of Industry and Information Technology launched a pilot allowing wholly foreign-owned value-added telecom services (VATS) — including internet data centres, cloud computing and online data processing — in Beijing, Shanghai, Shenzhen and Hainan. By early 2025, around 13 foreign-invested firms had been approved under the programme, including affiliates of large multinationals.
Here the "pilot, not switch" point is sharp. Removing the foreign-equity cap does not remove the VATS licence itself, the security review, or the data-localisation and cross-border-transfer obligations that data-heavy telecom businesses carry. The cap is one gate of several; the others stay shut until you clear them.
5. Why a "pilot" is not "nationwide law"
The single most common — and expensive — misreading is to treat a pilot, or a five-year-plan sentence, as a right that applies to your business everywhere. It usually does not. Three filters separate a headline from an executable plan:
- Geography. Most service openings are tied to specific cities, free-trade zones or Hainan — not the whole country. If your intended location is not on the list, the opening is not yours yet.
- The licence beneath the cap. An ownership opening removes one restriction; the operating licence, sector regulator's approval, and security review underneath it remain.
- Signalling vs. enacted list. A plan announces intent; a negative list or ministry measure creates the right. Always check which one you are relying on.
We set out how to run these checks in detail in "Removed from the negative list" ≠ open: five checks — the companion piece to this one. This article is the map of where the opening is pointed; that one is the checklist for confirming a given opening is real before you spend.
6. What foreign investors should do now
Treat the services pivot as a genuine, multi-year opportunity — and diligence it like one. Three practical moves. Match the pilot to your footprint: if healthcare or VATS is your play, the pilot cities decide where you can actually incorporate. Build the data overlay in from day one: telecom, data-centre and healthcare businesses sit squarely inside China's data regime, so map cross-border data transfer early — see PIPL cross-border data transfer and, for the relaxations, Shanghai's data export negative list. And keep security review on the radar: opening a sector to foreign ownership does not switch off the foreign-investment security review that can still apply where control of a sensitive business changes hands — we cover that gate in China's foreign-investment security review.
For the four-service overview and how the firm helps foreign companies scope entry, see China market entry. The opening is real; the discipline is to act on the version that is actually in force for your sector and your city.
Frequently asked questions
Yes, but selectively. The 15th Five-Year Plan (2026–2030) makes services the main frontier of the next opening — naming telecom and the internet, healthcare, education and culture — and China is delivering it through city-by-city, sector-by-sector pilots rather than a single nationwide change. Manufacturing restrictions are already at zero.
In the pilot locations, yes. A late-2024 pilot allows wholly foreign-owned hospitals in nine cities and areas — Beijing, Tianjin, Shanghai, Nanjing, Suzhou, Fuzhou, Guangzhou, Shenzhen and the whole of Hainan. Previously a foreign investor generally needed a Chinese partner holding at least 30%. Outside those locations, and beneath the ownership change, the usual health-sector licensing still applies.
In the pilot areas, yes. A late-2024 MIIT pilot allows wholly foreign-owned VATS — including data centres, cloud and online data processing — in Beijing, Shanghai, Shenzhen and Hainan, and around 13 foreign-invested firms had been approved by early 2025. Removing the equity cap does not remove the VATS licence, security review or data obligations underneath it.
The 2024 edition, with 29 items, effective 1 November 2024, under which restrictions on foreign investment in manufacturing have been reduced to zero. Services expansion under the 15th Five-Year Plan is a direction of travel; confirm the current list and any applicable pilot rules before relying on an opening.
No. A five-year plan states direction and intent; the legal right to invest is created only when a negative list, ministry measure or pilot notice actually issues. Rely on the enacted instrument for your sector and location, not the plan alone.
Sources
- China Briefing — China's 15th Five-Year Plan: key insights for foreign investors (services focus; pilots in VATS, biotech and wholly foreign-owned hospitals).
- China Briefing — China expands access for wholly foreign-owned hospitals in nine cities; gov.cn — wholly foreign-owned hospitals in major cities.
- China Briefing — guide to China's foreign investment negative list (2024 edition, 29 items; manufacturing at zero).
- Internal: "Removed from the negative list" ≠ open: five checks; China's foreign-investment security review; PIPL cross-border data transfer.
This article is general information for foreign companies, not legal advice on any specific matter. Rules and practice change; please take advice on your facts.