Sensitive sector screens · 03 Editorial guide
Foreign Investment in Sensitive Sectors: Telecom, Data and Key Technology
Infrastructure, key technology, data and resources overlays on the same deal.
First job List sector overlays that can trigger extra review even when access looks open.
Use this route when a signing, long-stop or filing clock will change the next step. Confirm current rules on the national decision desk.
Direct answer
What this page decides
01
This page owns FDI05 (telecom/internet) and FDI06 (sensitive tech/data) on one L4. It is an overlay list: VATS/ICP, data assets, cyber, controlled technology, infrastructure, finance/culture internet products. Supporting children such as /china-fdi-nsr-key-technology and /china-fdi-nsr-data-platforms stay screens, not rival hubs. Access still starts on the Negative List L4; process clocks on NSR process.
At a glance
Which fact changes the next route
Use the fact that changes ownership or urgency to decide the next move.
| Question | Why it matters | Next route |
|---|---|---|
| ICP/VATS/cloud? | Telecom overlay. | Licence + list + NSR. |
| Important data / large PI? | Data + possible NSR. | Data hub + this overlay. |
| Dual-use tech? | Export-control centre too. | Do not duplicate that centre. |
Scope
What this page owns — and what it does not
Practical workflow
Action, evidence, legal gate, output
| Action | Documents / evidence | Legal gate | Output |
|---|---|---|---|
| List sector tags | Licences, products, customers | Honest tagging | Overlay list |
| Telecom/internet | VATS, ICP, ownership caps | Access L4 + MIIT path | Telecom memo |
| Data and technology | Data map, IP, military/civil mix | NSR + data + export-control | Sensitivity memo |
| Pass to process | Trigger facts | NSR process L4 | File/no-file hypothesis |
Documents
What to gather before the next call
These items help clarify the file; they are not a legal requirement list.
| Item | Why needed | Who holds it | Risk if missing |
|---|---|---|---|
| Licence matrix | Telecom/finance/culture | Target | Hidden VATS |
| Data inventory summary | NSR/data | IT | Under-described platform |
| Tech and customer mix | Key technology screen | Product | Civilian label on sensitive use |
Common failure points
Where files usually break
‘We are just software’ with government and infrastructure customers.
FAQ
Narrow follow-ups owned by this page
Is every internet business NSR?
No. Overlay facts, control and the Measures decide. This page lists the questions.
Quick answers
Need the short version? Start with one narrow question.
These explainers answer one question. They do not replace this topic route or a deep guide.
Curated resources
Open the asset that matches this job.
Counsel hand-off
What to bring when you instruct
Instruct FDI counsel with telecom/data specialists as tagged. Bring: licences, data sketch, and customer types.
Local context
Add the city only when it changes implementation.
Local filing windows can matter after the national gate list is clear.
Open city and province guidesCounsel hand-off
Need FDI counsel?
This hub organises gates. It does not decide clearance on your facts.
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Who reviewed this guide
Need qualified counsel?
Move carefully. Move with a record.
Use the portal to identify counsel for this practice and related China-side issues.