Regulatory Update: Credit Repair Mechanism under China’s Corporate Social Credit System
Article by CNBW member CMS, China
Philipp Senff Jean Tian 
Corporate Reputation in China
Regulatory Update of the Credit Repair Mechanism under China’s Corporate
Social Credit System
China's National Development and Reform Commission (NDRC) has released most recently a new regulation in conjunction with the so-called "Credit Repair" mechanism of the Corporate Social Credit System (CSCS). The Administrative Measures for Credit Repair (Measures ) have been promulgated by NDRC on 20 November 2025 and will become effective on 1 April 2026.
1. Credit Repair
Credit repair means, in essence, that a company, which has been subject to negative records in the public credit databases (abbreviated in the system of CSCS with the term "Dishonest Information) has applied successfully for the removal of such negative records. The successful removal of negative records shall improve the credit standing of the affected company and the credit platform operators shall not use or share anymore the removed negative records with the competent authorities and
institutions. Therefore, companies operating in China need to be aware of this credit repair mechanism, to manage their corporate reputation in China. The Measures aim to further develop and unify the credit repair mechanism.
2. Categorization of Dishonest Information
The Measures categorize Dishonest Information into three levels based on severity, each with a different publicity period as follows:
Level 1 "Serious Dishonest Information" records are triggered in the following situations:
extremely large fines, suspension of permits or licenses, downgrading of qualification grades, revocation of permits or licenses, restrictions on production or business operations, orders to suspend production or business, orders to close down, or restrictions on engaging in specific business activities, being listed in the List of Seriously Dishonest Subjects, repeated violations without correction. The publicity period of "Serious Dishonest Information" records ranges between 1 to 3 years.
Level 2 "General Dishonest Information" records are triggered in the following situations:
large fines, or confiscation of illegal gains or property. The publicity period of "General Dishonest Information" records ranges between 3 months to 1 year.
Level 3 "Minor Dishonest Information" records are triggered in the following situations:
warnings or public reprimand, small administrative fines, being listed in the List of Enterprises with Abnormal Business Operations. The publicity period of "Minor Dishonest Information" records is up to 3 months. It could be also possible that the such records will not be displayed in a public database.
The application for the credit repair may be only conducted after the minimum publicity period has expired. Once the maximum publicity period has been reached, the records shall be removed automatically.
Further, competent industry authorities may formulate specific classification standards in their respective fields. If competent industry authorities have already established specific classification standards, such standards shall prevail.
3. Requirements for Credit Repair
Article 14 of the Measures provides that the following requirements shall be fulfilled for the application of the credit repair:
(1) The minimum publicity period has been expired;
(2) The wrongful credit conduct has been rectified, and all obligations as required by the administrative penalty, the List of Enterprises with Abnormal Business Operations, or the List of Seriously Dishonest Subjects have been fulfilled;
(3) A public credit commitment has been made, affirming the authenticity and validity of the submitted documentation, and expressing the willingness to bear corresponding responsibility in case of breach; and
(4) Other conditions as required by laws, administrative regulations, or departmental rules have been fulfilled.
Article 15 of the Measures clarifies the required application documents for the credit repair, which are the following:
(1) Supporting materials evidencing the rectification of the wrongful credit conduct and the performance of legal obligations;
(2) A formal credit commitment letter; and
(3) Other materials as required under laws, administrative regulations, and departmental rules.
4. Digital Submission for Credit Repair
The application for credit repair shall be submitted digitally through the website of "Credit China", which then forwards these applications to the authority, which has issued the Dishonest Information.
5. Timeline: 10 plus 10
The "Credit China" website shall respond to the affected company within 10 (ten) working days with the result of the applied credit repair. The 10-day working timeline commences from the date of receipt of the application for credit repair. This timeline may be extended for another 10 (ten) working days, if the case is complex.
6. Punishment of Fake Applications
Article 25 of the Measures strictly prohibits providing wrong information in conjunction with the application of credit repair. Specifically, if a company provides fraudulent materials, makes a seriously false credit commitment, or is determined by the relevant authority to have intentionally failed to fulfill its commitment, such conducts shall be recorded in the credit record. This credit record shall be
publicized on the "Credit China" website for a period of three years, which shall not be removed in advance. This could significantly damage the reputation of the affected company given that the website "Credit China" may be accessed free of charge and globally. Further, the original Dishonest Information shall not be eligible for credit repair applications within these three years. If such conduct constitutes a crime, criminal liability shall be pursued according to the law.
(Newsletter article - PDF - here)
Contact:
Philipp Senff
Head of Compliance, CMS, Shanghai
+86 21 6289 6363, philipp.senff@cmslegal.cn
Jean Tian
Associate, CMS, Shanghai
+86 21 6289 6363, jean.tian@cmslegal.cn