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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.

Decision railaccess result → sector overlay → data/tech facts → NSR likelihood → parallel licences
See routing facts
Closing cannot outrun uncleared gates

Use this route when a signing, long-stop or filing clock will change the next step. Confirm current rules on the national decision desk.

Open the national FDI decision desk

Direct answer

What this page decides

Owner
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.

Facts that change the next investigation route
QuestionWhy it mattersNext 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

Owns FDI05 + FDI06.
Exclusionsfull PIPL export path (Data hub); dual-use licensing (export-controls centre).

Practical workflow

Action, evidence, legal gate, output

Practical workflow
ActionDocuments / evidenceLegal gateOutput
List sector tagsLicences, products, customersHonest taggingOverlay list
Telecom/internetVATS, ICP, ownership capsAccess L4 + MIIT pathTelecom memo
Data and technologyData map, IP, military/civil mixNSR + data + export-controlSensitivity memo
Pass to processTrigger factsNSR process L4File/no-file hypothesis

Documents

What to gather before the next call

These items help clarify the file; they are not a legal requirement list.

Documents to gather before instructing counsel
ItemWhy neededWho holds itRisk if missing
Licence matrixTelecom/finance/cultureTargetHidden VATS
Data inventory summaryNSR/dataITUnder-described platform
Tech and customer mixKey technology screenProductCivilian label on sensitive use

Common failure points

Where files usually break

  1. ‘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 guides

Counsel hand-off

Need FDI counsel?

This hub organises gates. It does not decide clearance on your facts.

Find investment counsel

Submit an initial enquiry

Need qualified counsel?

Move carefully. Move with a record.

Use the portal to identify counsel for this practice and related China-side issues.