Complete the role card, test channels by candidate source, and advance only through each gate. Recruitment information must be truthful, role-related, and free from unlawful discrimination; résumés and background materials follow the minimum-necessary standard. An offer is not a labour contract; foreign candidates cannot work on a trial basis before work authorization and work-type residence permission. Plan by role, city, notice period, and permission process rather than promise fixed days.
KEY TAKEAWAYS
Key takeaways
- Use the actual work city, employing entity, duties, location and hours, pay range, language, and work-permission conditions to write the role card.
- Treat the company website, local recruitment platforms, campuses, public employment services, licensed HR agencies or headhunters, and employee referrals as a testable channel mix, rather than betting on unverified rankings.
- Set funnel gates for role authenticity, compliant screening, interviews and reasonable accommodation, information handling, offer and contract, and onboarding permissions.
- Break the recruitment timeline into preparation, channel response, screening and interviews, candidate notice period, contract and onboarding, and foreign-candidate permissions.
Start with the conclusion: Recruitment does not begin with an advertisement; it begins by locking down employment conditions
Before recruiting, a China business confirms the employing entity, where the employee will actually work, the responsibilities to be assumed, and the work qualifications a candidate needs, then chooses platforms. If the role card is incomplete, résumé screening, interviews, offers, and permission applications will keep changing their criteria.
Remember the process in two sentences: first use a recruitment-channel hypothesis board to decide where to seek candidates on a small scale; then use recruitment-funnel gates to decide who may move to the next step. This helps foreign founders and China teams divide work while retaining reviewable records of recruitment rationale, candidate information, and decisions.
1. Build the role card first: Turn “who are we seeking?” into screenable conditions
A role card should state at least eight groups of information: the actual work city and district, not only “nationwide” or the registered address; the full name of the employing entity, and confirmation that it can enter into a labour contract; responsibilities, reporting line, and work to be delivered after joining; office location, travel scope, and on-site, hybrid, or remote arrangements; working time, rest and leave arrangements, and pay range; the actual use settings for Chinese, English, or other languages; education, experience, skills, or qualifications required for the role; and, for foreign candidates, whether work permission is needed, the type of permission, and preconditions for onboarding.
The role card is not an internal wish list. Recruitment information should be truthful, lawful, and valid, and at least tell candidates the recruiting entity, headcount, conditions, work content, location, and basic remuneration. If an HR service agency publishes it, the company should give the agency a confirmed recruitment brief, rather than allowing an intermediary to add restrictions itself. Both the Interim Regulations on Human Resources Markets and the Regulations on Online Recruitment Services require recruitment information to be truthful and lawful and oppose household-registration, regional, or identity restrictions unrelated to the role. The Labour Contract Law also requires the employer to truthfully inform candidates about work content, conditions, location, occupational hazards, and remuneration. Labour Contract Law
Divide the role card into “must have,” “can be developed,” and “verify in interview.” For example, client-development experience may be a must-have for sales; use of a particular CRM can be developed; and willingness to travel should be verified in interview with its frequency stated. Do not disguise nationality, sex, age, marriage or childbearing, or personal-life questions unrelated to responsibilities as capability requirements. Where a role genuinely has statutory qualifications, a specific work environment, or foreigner-permission limits, state the legal or business basis and have professionals review the wording.
2. Choosing channels: Use a recruitment-channel hypothesis board, not platform rankings
Write each channel as a hypothesis to be tested. Record the test action and evidence before asking “which platform is best?” A channel hypothesis board can have five cells: candidate hypothesis, channel, test action, evidence needed to advance, and stop conditions.
A company website suits people who already know the company or actively search for the brand. A test can publish a clear role card with a dedicated submission route and observe whether résumés meet baseline conditions. Local recruitment platforms suit roles needing a larger candidate pool, but the business should first check the service entity, fees, information permissions, and content-review rules of the platform and any recruitment agent. Campus channels suit graduate or development roles, and should clearly distinguish graduation date, internship, and formal employment. Public employment services can be a lower-cost supplement. Public HR service institutions lawfully provide job, market-wage, vocational-training, placement, and guidance information; specific services depend on local institutions. Relevant FAQs on the Interim Regulations on Human Resources Markets
Licensed HR service agencies and headhunters suit scarce, confidential, or actively sourced roles. Before cooperation, check their HR-service licence or legally filed scope and require written terms covering candidate-information source, purpose, retention, deletion, confidentiality, and fees. Employment intermediation, online recruitment, and senior-talent search are all regulated service types. Regulations on Human Resources Service Agencies Employee referrals may use trust relationships, but referrers cannot perform discriminatory screening for the business or forward candidate information freely to personal groups.
The China Public Recruitment Network and the Ministry of Education's National College Student Employment Service Platform (24365) are official channel examples, not evidence of coverage or effectiveness ranking. Employers on 24365 must register and undergo review under platform rules; the platform provides job posting, résumé screening, interview notice, and related functions. Businesses should follow the current platform rules. China Public Recruitment Network Ministry of Education notice on the National 24365 platform
For every channel, retain only data that answers “does this candidate fit the role card?” Review measures can include the proportion of qualified résumés, interview conversion, candidate duplication, cost per candidate record, and response speed. Do not conclude “largest platform” or “market number one” without reliable sources.
3. Process: Set five gates for the recruitment funnel
Set the recruitment funnel as five gates. Gate 1 is authorization: confirm who approves the role, which entity contracts, and who may see résumés. Gate 2 is the role card: city, responsibilities, working arrangement, pay range, and permission conditions are final; any newly added restriction must return to this gate and state its rationale. Gate 3 is source: record whether a candidate came from the website, platform, campus, public service, agency, or referral, and retain a route that tells the candidate how their information will be used.
Gate 4 is screening and interview: judge only from role-related experience, skills, work samples, language, availability, and working arrangement. Interviews may ask about experience needed to perform role tasks and explain hours, location, travel, and pay structure, but must not use marriage, pregnancy, family-planning, family care, or health details unrelated to work as screening conditions. When a disabled candidate requests reasonable accommodation, first discuss role tasks, assistive devices, accessibility arrangements, and safety requirements; do not reject the person from a diagnostic label. The Law on the Protection of Disabled Persons requires non-discrimination in employment and suitable working conditions and labour protection.
Gate 5 is the decision: record role-related reasons for passing or not passing internally and send the candidate a clear notice of the next step. Publishers, reviewers, and employers of recruitment information are all responsible for it. The current human-resources notice requires conditions to be set by role need and prohibits sex, exclusion of a specified ethnic group, or age and other restrictions unrelated to the role. Notice on Standardizing Recruitment Information and Promoting Equal Employment The route for a job seeker to pursue an employment-discrimination matter should be considered with the facts through the local human-resources authority or qualified professionals.
4. Recruitment information and interviews: Put equal employment into every gate
The Employment Promotion Law gives workers equal employment and independent job-choice rights, and requires employers and employment intermediaries to offer equal opportunity and fair conditions. Women may not be refused, or have admission standards raised, because of sex, unless law provides that the job is unsuitable for women. An advertisement saying “men only,” “men preferred,” or making marriage and childbearing a threshold cannot be justified as an “internal habit.” Employment Promotion Law
The Law on the Protection of Women's Rights and Interests sets more specific recruitment boundaries: unless otherwise provided by the State, employers may not ask about or investigate a female job seeker's marriage or childbearing status, include a pregnancy test in pre-employment physical examinations, make marriage, childbirth, or marital status a hiring condition, refuse employment because of sex, or raise admission standards because of sex. Law on the Protection of Women's Rights and Interests
Hepatitis B requires separate treatment. Ordinary recruitment and entry physical examinations may not require hepatitis B virus carriers to provide test reports or ask whether they are carriers, and may not reject someone only because of carrier status. National health-authority documents retain exceptions for special occupations provided by law or approved under law. Where an ordinary role genuinely needs a work-related health and safety assessment, perform only necessary items; do not expand it into hepatitis B screening. Notice on Further Standardizing Physical Examination Items for Admission and Employment and Protecting the Rights of Hepatitis B Surface-Antigen Carriers
In practice, give interviewers an “ask / do not ask” card. They may ask about role tasks, work samples, technical methods, language use, office location, and travel arrangements. They may not ask about childbearing plans, illness unrelated to the role, or family privacy. If a safety-sensitive role genuinely has a statutory medical-examination requirement, state the requirement, basis, and scope in the role card and have HR or professional advisers check it before the interview.
5. Résumés, background checks, and vendors: The minimum necessary standard is executable
A résumé is not better simply because it is more complete. Before collecting information, tell candidates the recruitment purpose, use scope, retention period, contact method, and deletion or withdrawal route. Collect only names, contact details, experience, work samples, qualifications, and availability genuinely needed for screening and onboarding. Identity documents, precise addresses, financial accounts, health records, biometric information, and similar material require separate necessity assessment. The Personal Information Protection Law requires a clear and reasonable purpose and minimum scope for personal-information processing. Sensitive information such as medical and health information may be processed only for a specific purpose where sufficiently necessary and with stricter protective measures. Personal Information Protection Law
Recruitment software, headhunters, background-check companies, and overseas headquarters may all receive personal information. Contracts should state purpose, duration, method, information types, security measures, deletion or return, subcontracting restrictions, incident notice, and audit cooperation. After recruitment, delete or anonymize data under internal retention rules; do not retain it indefinitely because it “may be useful later.” The Personal Information Protection Law imposes corresponding notice, contractual, or consent arrangements for entrusted processing, provision to other processors, and sensitive-information processing; the exact route depends on the information type and processing setting.
If an overseas HR system or vendor can access China-candidate résumés, first assess whether this constitutes providing personal information overseas, then check applicable notice, separate consent, impact assessment, standard contract, or other mechanisms. The 2024 cross-border data provisions provide particular facilitation for cross-border HR management under lawfully made labour rules and lawfully concluded collective contracts, but they do not remove personal-information protection obligations. Where the standard contract for export of personal information is used, complete a personal-information protection impact assessment before export and file it as required. Provisions on Promoting and Regulating Cross-Border Data Flows Measures on the Standard Contract for the Export of Personal Information
Keep five points for background checks: lawful basis, prior notice, candidate authorization, role relevance, and confidential results. Criminal records are not ordinary search material. Where an organization checks criminal records of a current or proposed employee, it must have a specific legal or administrative-law basis concerning employment prohibition and submit materials explaining the proposed employment relationship and legal basis. Results may be used only for the corresponding purpose and are subject to confidentiality obligations. Provisions on Public-Security Authorities Handling Criminal Record Inquiries For ordinary roles without a clear basis, do not buy “blacklists” or request criminal records from unauthorized people.
6. Offers, labour contracts, and employing foreign nationals: Do not confuse pre-onboarding documents
An offer is a document through which an employer presents hiring terms to a candidate. A labour contract is the formal agreement establishing and defining the employment relationship; the two cannot simply be equated. An offer should state role, location, pay structure, expected start date, conditions, and validity, and make clear that the final basis is the labour contract lawfully signed by both parties. If actual employment has already begun, a written labour contract cannot be omitted simply because an offer was sent. The Labour Contract Law provides that the employment relationship begins on the date work begins, requires a written labour contract when an employment relationship is established, and lists important matters including work content and location, working time, remuneration, and social insurance. Labour Contract Law
Set a separate permission gate for foreign candidates. The Exit and Entry Administration Law requires foreign nationals working in China to obtain the corresponding work permit and work-type residence document, and prohibits any organization or individual from employing a foreigner without the corresponding permission. Work outside the permission scope may also constitute illegal employment. Exit and Entry Administration Law Ordinary long-term employees generally follow the work-permit plus work-type residence-document route. Short-term work has separate rules for work permits, Z visas, and connection to stay or residence arrangements, which should be checked by duration and activity. The multi-department Guide for Foreign Businesspeople Working and Living in China (2025 Edition) provides a current entry point. Do not treat the old “Foreigners' Employment Permit” as today's operating name, and do not let a candidate “try the job first” before completing procedures.
Confirm materials and handling locations for the applicable visa, stay document, or work-type residence document against current guidance from the National Immigration Administration and the local exit-entry administration. Work permits, exit-entry documents, and the actual role, city, and duration must match each other. Service Guide for Foreigners' Residence Permits Until permission and exit-entry documents matching the intended work duration and activities are approved, a company may conduct remote communication, prepare materials, and arrange interviews that are not employment in nature, but may not have the candidate actually perform role work as “training,” “probation,” or unpaid work.
7. Estimating the timeline: Plan with variables, not fixed-day promises
A recruitment timeline can be managed with a simple model: time to prepare the role card, plus channel response, screening and interviews, the candidate's notice period, offer and contract, onboarding preparation, and, for foreign candidates, applicable work-permit and work-type residence-permission stages. Each can be affected by role scarcity, city, pay competitiveness, number of decision-makers, whether the candidate is employed, completeness of materials, and review by competent authorities.
Do not promise clients, candidates, or directors that someone “will definitely start in 7, 14, or 30 days.” A safer approach gives conditional ranges: when the role card will be complete, when the first channel round starts, who decides each interview round, how the candidate's notice period is confirmed, and which official window and material list apply to foreign permission. Review funnel-gate pass rates and causes of blockage weekly; do not lower screening standards to chase a number of days.
8. Three fictional scenarios: Applying the same framework
Fictional scenario 1: A Shanghai sales role
A company preparing to operate in Shanghai puts client sector, Chinese-language use, travel scope, and pay range into the role card. It first tests its known network through the company site and employee referrals, then gives the same truthful information to a local recruitment platform. Interviews verify only client-development examples, work location, and travel arrangements, not marriage or childbearing. If a candidate comes through the platform, the business first checks authorization for platform résumé collection and deletion mechanisms. If the pay structure changes, it returns to the role-card gate for approval.
Fictional scenario 2: A Shenzhen hybrid-work engineer
The team documents the actual Shenzhen office address, weekly on-site collaboration arrangement, code-repository permissions, English-meeting setting, and acceptable remote equipment. Campus channels test development candidates; specialist platforms and employee referrals test experienced candidates. Interviews use code samples and troubleshooting discussion, not home address to infer commuting reliability. If a candidate requests assistive equipment, discuss reasonable accommodation required for the role first. Background checks verify only education and work experience that are relevant to the role and have been disclosed and authorized.
Fictional scenario 3: A Beijing foreign manager
The company writes management responsibilities, actual work city, reporting line, language settings, and work-permission conditions into the role card. The offer is conditional on permission and a lawfully signed labour contract; the team does not schedule the person to come to the office to “try for a few days.” Recruiters separately check that work permit, visa, and applicable stay or residence documents match the role location and duration, and treat whether overseas headquarters can access résumés as a cross-border personal-information issue rather than uploading résumés directly to a global system.
All three scenarios show that every decision returns to the role card, channel hypothesis, and funnel gate; a candidate's private life is not a screening tool.
9. Implementation checklist for foreign founders and HR
Before recruitment starts, confirm the China employing entity, actual work city, role card, budget, and approver, then select one or two complementary channels for small-scale testing. Before publishing, have HR or legal advisers check wording about sex, marriage and childbearing, hepatitis B, age, household registration, and identity. Before receiving résumés, prepare privacy notice, retention and deletion rules, and vendor agreements. Before interviews, give interviewers an ask / do not ask list. Before background checks, confirm lawful basis, notice, and authorization. Before issuing an offer, state its relationship to the labour contract. Before hiring a foreign national, treat work permit, visa, and applicable stay or residence documents matching work duration and activities as gates.
If you are entering the China market and need company-registration coordination, material preparation, or support from partner institutions, see China Company Registration Services. The service boundary on that page is registration-related coordination and material support. It does not replace employer responsibility for recruitment, employment, payroll and social insurance, or immigration permissions, and does not guarantee registration, recruitment, permission, or approval outcomes. Labour, personal-information, and exit-entry matters should be reviewed by appropriately qualified professionals in light of the actual circumstances.
This article provides only a recruitment-process and checking framework. It does not constitute labour, tax, immigration, or personal-information legal advice.
SOURCES
Sources
- Employment Promotion Law of the People's Republic of China (Ministry of Human Resources and Social Security)
- Labour Contract Law of the People's Republic of China (State Administration for Market Regulation)
- Law of the People's Republic of China on the Protection of Women's Rights and Interests (reproduced by the Ministry of Industry and Information Technology's Guangzhou Office)
- Interim Regulations on Human Resources Markets (Ministry of Justice Administrative Regulations Database)
- Regulations on Online Recruitment Services (Beijing Municipal People's Government Policy and Regulations Database)
- Notice on Standardizing Recruitment Information and Promoting Equal Employment (reproduced by Changzhi Human Resources and Social Security Bureau)
- Notice on Physical Examination Items for Admission and Employment and Rights of Hepatitis B Surface-Antigen Carriers (National Health Commission)
- Personal Information Protection Law of the People's Republic of China (Cyberspace Administration of China)
- Provisions on Promoting and Regulating Cross-Border Data Flows (Cyberspace Administration of China)
- Measures on the Standard Contract for the Export of Personal Information (Cyberspace Administration of China)
- FAQs on Public Employment Services Related to Human Resources Markets (Ministry of Human Resources and Social Security)
- China Public Recruitment Network (Ministry of Human Resources and Social Security)
- Notice on Matters Concerning the National 24365 College Student Employment Service Platform (Ministry of Education)
- Regulations on Human Resources Service Agencies (Ministry of Human Resources and Social Security)
- Exit and Entry Administration Law of the People's Republic of China (National Immigration Administration)
- Service Guide for Foreigners' Residence Permits (National Immigration Administration)
- Guide for Foreign Businesspeople Working and Living in China (2025 Edition) (Ministry of Commerce)
- Provisions on Public-Security Authorities Handling Criminal Record Inquiries (Beijing Municipal People's Government Policy and Regulations Database)
- Law of the People's Republic of China on the Protection of Disabled Persons (National People's Congress)