Safeguarding in international schools in China: a DSL guide

This guide covers mainland China. Hong Kong has its own rules, so read the Hong Kong guide if that is your school. Start by working out which kind of school you run.

A school for the children of foreign personnel is approved by the provincial education department. The Ministry of Education (MoE) gives policy guidance. A 2014 MoE opinion also asks provinces to inspect these schools each year or run accreditation reviews.

Under the MoE interim measures from 1995, these schools may enrol children of foreign nationals who hold residence permits. They may not enrol Chinese citizens' children. They must file staff and student lists with the local education authority each year and accept its inspection.

Schools that enrol Chinese citizens follow other rules. Under the Regulations on Chinese-Foreign Cooperation in Running Schools, cooperative institutions cannot run compulsory education. A provincial education department approves the secondary ones.

Accreditors sit on top of the licence and never replace it. The UK Department for Education lists accredited British Schools Overseas in mainland China, and the Western Association of Schools and Colleges (WASC) lists China too. Ask your Head which other bodies your school holds, such as the Council of International Schools (CIS) or the International Baccalaureate (IB).

The main law is the Law on the Protection of Minors. It was revised in 2020, amended in 2024 and has applied since 1 June 2021. Article 131 says it also protects foreign and stateless children in China.

Schools must ban corporal punishment and humiliating treatment (Article 27). They must run a bullying prevention system and train staff and students on it (Article 39). They must also run a system to prevent sexual assault and harassment (Article 40).

A school may not hide sexual assault or harassment of a child. It must report promptly to the police and the education authority and help them (Article 40).

If a school breaks Article 27, 28 or 39 and refuses to fix it, or the case is serious, the people directly responsible can face discipline (Article 119). Article 130 defines bullying as deliberate or malicious oppression or insult between students that causes injury, loss or mental harm.

The laws in this guide were read in the National People's Congress law database on 19 October 2026. This is general information, not legal advice. Confirm current law with local counsel and the relevant authority.

Yes. Article 11 of the Law on the Protection of Minors tells organisations that work closely with children, and their staff, to report at once. Article 130 says these organisations include schools and kindergartens.

The duty starts when staff find, at work, that a child is harmed, may be harmed or faces other danger. The report goes to the police, civil affairs or education departments. The civil affairs department has child welfare powers, including guardianship in listed cases (Articles 92 to 94).

The Anti-Domestic Violence Law adds a duty for schools. Staff who find a child suffering or suspected of suffering domestic violence must report promptly to the police (Article 14). The police must keep the reporter's details private.

If a person fails to report and serious harm follows, Article 117 allows discipline for those directly responsible. Mandatory reporting laws for international schools compares other countries.

Article 11 names both the organisation and its staff. Whether telling your designated safeguarding lead (DSL) meets each person's own duty is a question for local counsel.

If a child is in immediate danger, call 110 for the police, then tell your DSL. Call 120 for an ambulance and 119 for fire. The UK government's travel advice for China lists these numbers.

Name staff who speak Mandarin and can make the call with you. Write their mobile numbers next to the police number.

For advice, ask your local education bureau which child protection hotline your district runs. Article 97 says governments at county level and above must open a national unified minors' protection hotline. It receives complaints and reports and passes them on.

This guide could not confirm a single national child helpline number from a Chinese government source, so it prints none. Call any number yourself before you put it in your procedure.

Put 110, 120 and the DSL's name and phone number on one page, in English and Chinese. Check the page each term.

Standards based on the International Task Force on Child Protection (ITFCP) ask staff to pass on any concern early. Keeping children safe in education (KCSIE) asks the same of schools in England. It has no legal force in China.

Article 11 starts the duty when staff find harm, possible harm or other danger. That fits the early-concern habit well. Staff still need to know who makes the call and how fast.

One procedure can serve both. Staff tell the DSL at once. The DSL decides without delay on a report to the police, civil affairs or the education authority, and records who decided and when.

Three differences need care in your wording.

• Home discipline: the law gives parents a duty of "reasonable discipline" (Article 16). Your policy should still ask whether a child has been harmed.
• Sexual assault and harassment: a school may never hide them (Article 40), so no case is handled quietly inside the school.
• Who reports: any person may report to the police (Article 11), so say staff can do so if the DSL is out of reach.

The Personal Information Protection Law (PIPL) took effect on 1 November 2021. Article 28 treats the personal information of children under 14 as sensitive. Article 31 requires a parent's or guardian's consent to process it.

Article 13 also lets an organisation process data it needs for a legal duty, such as a required report. Ask counsel which basis covers each part of a safeguarding file.

Sending personal information out of China needs a legal route. Article 38 lists routes such as a government security assessment, certification or a standard contract. Article 39 also requires telling the person about the overseas receiver and getting separate consent.

A 2024 Cyberspace Administration order sets size limits for each year. For 10,000 or more people, sensitive data sent abroad needs a security assessment. For fewer people, it needs a standard contract or certification unless an exemption applies.

Data on children under 14 is sensitive, so a safeguarding file sent abroad may need one of these routes. Ask counsel before you pick a supplier. Article 40 also requires some operators to store China-collected data in China, and Article 57 requires leaks to be reported.

Many support staff may speak only Mandarin. Write your reporting route in English and Chinese. Ask a Mandarin speaker who knows your procedure to check that the two versions say the same thing.

Families and staff may hold different views on discipline, privacy and who should be told. Ask each group what they expect. Then write down what your school does and why.

Corporal punishment is banned in schools (Article 27). The Global Initiative to End All Corporal Punishment of Children reports that it is still lawful at home. Your code of conduct should ban it for every adult, including contractors.

Article 62 says an organisation that works closely with children must check each applicant with the police and the procuratorate (state prosecutors). The check covers records of sexual assault, abuse, trafficking and violent injury. The organisation must not hire anyone with such a record.

Ask counsel how Article 62 works for foreign applicants, because a Chinese check covers China only. China has been party to the Apostille Convention since 7 November 2023, which can simplify paperwork for police certificates from other member countries. Ask for checks from every country a candidate has lived in, as set out in safer recruitment for international schools.

Use this list in your first month. Share it with your Head and your deputy DSL.

Laws change. Confirm anything here with local counsel and the relevant authority before you rely on it.

• Find out which authority approved your school and which licence you hold.
• Write one reporting route that names the DSL, the deputy, 110 and 120.
• Ask counsel whether telling the DSL meets each staff member's own duty under Article 11.
• Ask your education bureau which minors' protection hotline your district runs.
• Write down that sexual abuse or harassment is never handled quietly inside the school.
• Ask counsel which legal route covers sending safeguarding records abroad.
• Ban corporal punishment in writing for every adult, including contractors.