Coronavirus: Employer Requirements to Resume Operations in Select Major Cities in China

February 26, 2020

As employers in the People’s Republic of China have proceeded or attempted to resume operations since the end of the extended Spring Festival period in early February, they have faced various preapproval and filing requirements imposed by local governments based on several epidemic prevention and control measures implemented to control the spread of the 2019 Novel Coronavirus.

As the 2019 Novel Coronavirus (COVID-19) situation gradually improves, China’s central government has made clear that it (and employers) shall take steps to bring the economy and operations to a normal level, while upholding the many efforts to control the spread of COVID-19. In response, many provinces and municipalities have taken various steps to assist entities to resume operations.

However, millions of workers across China have not yet traveled back to their work locations from their hometowns, where they went for the annual Spring Festival celebrations. Thus, to reduce the risks of contagion some jurisdictions are arranging dedicated transportation for workers returning to work from their hometowns or providing dedicated shuttle bus services for employees commuting to work, as well as resolving other transportation difficulties.

As of February 21, 2020, some jurisdictions have relaxed and/or lifted, or will relax, some or all of their preapproval and filing requirements so employers that meet the COVID-19 prevention and control requirements can promptly resume operations without unnecessary delay. However, even as the preapproval and filing requirements are gradually phased out, the prevention and control requirements will likely stay in place for the near future.

We have created a chart of the preapproval and filing requirements in select jurisdictions across China. With respect to Hubei Province, the province where Wuhan is located, the resumption of operations may not take place before March 11, 2020, so neither the provincial government nor the Wuhan municipal government has issued any regulations on what steps are necessary to resume operations.

See the chart of preapproval and filing requirements for select jurisdictions in China >>


If you have any questions or would like more information on the issues discussed in this LawFlash, please contact any of the following Morgan Lewis lawyers:

K Lesli Ligorner
Yuting Zhu