Can Your China Recruiter Name Your Rivals’ Hires?

Recruitment Partners

Can Your China Recruiter Name Your Rivals’ Hires?

Most foreign employers compare search firms for weeks and verify one for an afternoon. This piece is about the afternoon. It assumes you already know what you want to hire, and takes up the part nobody puts in the procurement file.

By SunTzu Recruit　｜　Data as of November 3, 2026

Sources: Provisions on the Administration of Human Resources Service Institutions, Ministry of Human Resources and Social Security Order No. 50, effective August 1, 2023 / Interim Regulations on the Human Resources Market / Interim Provisions on the Administration of Foreign-Invested Talent Intermediary Agencies / MOHRSS national human resources service statistics and the 39-city manufacturing integration pilot notice / provincial government service guides for the foreigner work permit process / ManpowerGroup Employment Outlook Survey Q4 2026 and Global Engineer Outlook 2026 / German Chamber of Commerce labour market and salary report 2025-2026 / Liepin recruitment cycle data

At a glance

• Headhunting is a licensed activity here. The regulation names senior talent search in so many words, and the licence number is a public record.
• 74,000 institutions share that licence, so holding one sorts almost nothing. What sorts firms is whether they can name five employers where your candidate already works.
• Two firms quoting 25 per cent can differ by 15,000 yuan on one hire, because the base is the variable and the rate is the argument nobody wins.
• Their engagement ends at signature. Everything that keeps your new hire legal starts after it, and belongs to whoever holds the entity.

The Licence Exists. Almost Nobody Asks.

Start with the part already written down.

Under the Provisions on the Administration of Human Resources Service Institutions, in force since 1 August 2023, any agency that places candidates with employers must hold a human resources service licence issued by the human resources and social security bureau in the city where it is registered. The text does not leave the activity to inference. Job intermediation, it says, includes recommending candidates to employers, introducing employers to job seekers, running recruitment fairs, operating job boards, and providing 高级人才寻访 — senior talent search.

Headhunting in China is therefore the regulated activity, rather than an informal trade that grew up around a regulation. The domestic threshold is modest: a charter, a fixed office, three full-time staff. A foreign-invested talent intermediary faces more, with five full-time staff holding tertiary qualifications and a talent intermediation certificate. The bureau decides within 20 working days. An agency offering consulting, assessment or outsourcing without placing anyone files rather than applies, within 15 days of starting.

None of that is hard to check.

Ten minutes and one phone call

The licence number sits on the agency’s registration and in bureau records, and the scope has to cover senior talent search rather than advertising alone. Foreign buyers skip this step less from difficulty than from habit: the procurement template they bring to China has no field for it. Selection runs on references, case studies and a pitch. Locally, a factory HR manager asks whether the agency can issue a valid invoice and who it has placed nearby. The licence is assumed.

The assumption usually holds, and the exceptions cost you a search rather than a fine. Four activities sit in this market under four different documents, and a buyer who cannot tell them apart cannot tell what he is buying.

• Placing candidates. Needs the human resources service licence, applied for before trading. Verify the number, and that the scope mentions senior talent search.
• Consulting, assessment, training, outsourcing. Filing within 15 days of starting, no licence. A filing receipt is not permission to place anyone, and this is the distinction most often missed.
• Online recruitment platforms. An additional telecom business licence, with ICP filing held by the operating entity.
• Labour dispatch. A separate dispatch licence, and a separate business from search.

So the number counts everything from global firms with Pudong offices to two-person outfits working a single industrial park, and the registration does not separate them. A five-person agency and a firm with three offices across Asia hold the same document, and describe themselves in the same vocabulary, because the vocabulary came from the same place. The difference appears in month two, when the shortlist arrives and nobody on it works for a company you have heard of.

A Market That Grew Without a Specification

Scale arrived ahead of standards. At the end of 2024 the ministry counted 1.09 million practitioners in the market, delivering more than 50 million employer engagements and 300 million job-seeker engagements a year across the 14th Five-Year Plan period. Manufacturing takes close to 40 per cent of that volume, which makes factories the largest client group in the market and, on most accounts, the least equipped to compare what is being sold to them.

The state has noticed the mismatch. Thirty-nine pilot cities are integrating human resources services with manufacturing — fifteen in the east, nine in the centre, twelve in the west, three in the northeast — each required to pick one to three subsectors and work with the lead firms, single champions and specialised small firms inside them. Shanghai, Beijing, Guangzhou, Shenzhen, Suzhou, Ningbo, Hangzhou, Wuhan and Chengdu are all on the list. The intent is a supply side more specific than a general recruitment agency.

A question answerable with an adjective sorts nothing.

The pilots do not reach the deeper problem, which is that the product has no specification. Two agencies quoting 25 per cent can mean different things, because the base differs, the guarantee runs from different dates, and a repeat candidate is whoever the contract says it is. This is why the standard checklist — does the firm know your industry, does it have reach in your city — draws identical answers from firms whose capabilities are nowhere near identical.

There is a second reason it fails for foreign employers. Most of that checklist was written for companies with an HR department inside the country. Its assumptions do not survive the border: that someone local reads the CVs, that the interview happens next week, that an offer can be issued without approval from three time zones away.

Send the title, not the job description

Put the test in the first meeting. Do not send the job description. State the title, the city and the reporting line, then ask who holds that job now, at which five companies, what they are paid, and why any of them would move.

The reason to withhold it is that the description was written somewhere else. A title sitting in a global band has no direct equivalent in a Chinese organisation of forty people, and a firm that takes the document literally returns candidates who match the words. Most agencies can read an English description. Few can screen against one, because the difficulty is grading rather than language. Ask for the shortlist rationale in the language the hiring manager will interview in, and treat a fluent reply as a translation rather than a judgement.

Withholding the document is the smaller half of the test. What the firm does with a title, a city and a reporting line tells you more than what it does with a brief.

What a good answer sounds like

A firm that has worked your subsector answers from memory, including the parts that do not flatter you.

• “There are three plants within forty kilometres that do this work. The last person in your role came from the second one and left after eleven months.”
• “Your band sits below what the incumbents are on. At that number you are hiring for potential, and you will be training the person for the plant that takes them next.”
• “Two of the five you are thinking of have been losing process engineers to a line that opened across town this year.”

A firm working from a database returns a list of companies whose names appear in the keywords of your title. Both answers take the same thirty seconds. One of them you can verify by calling a competitor.

There is a version of this test with numbers attached. Liepin tracks the self-managed hiring cycle for senior R&D roles at 45 days five years ago and 68 days now, a 50 per cent lengthening that has little to do with candidate supply. It reflects approval layers, salary band reviews and the second and third interview rounds that head office adds from a distance. A firm that can name them can also tell you which layer to cut, and that layer is the only part of the delay you control.

The question nobody asks

Then ask where the previous holder came from and why they left. Employers rarely do, because it invites an answer about their own organisation. It is also the line between a partner and a supplier: one has looked, the other has not. A recruiter who can explain the exit is usually the one who can explain the entry.

What Does 25% Actually Buy?

The rate is the least interesting number on the page. Contingency and retained search in China commonly settle between 20 and 30 per cent of annual package, with 90 days of guarantee and 180 for senior appointments, and 30 to 50 per cent payable before the start date. These are conventions rather than a market price, and the firm quoting at the bottom of the range is often the more expensive of the two.

The base is the variable. A role at 30,000 yuan a month over 14 months is a package of 420,000 yuan, and 360,000 if the agency multiplies by twelve. At the same 25 per cent that is 15,000 yuan between two contracts quoting an identical rate. A buyer who spends the meeting arguing the rate down from 25 to 22 per cent has saved 10,800 and left the larger number on the table.

Then read the guarantee properly. Ninety days from the start date protects you against a hire who walks in the first quarter. Ninety days from the offer signature protects against very little, since the clock runs before the person has resigned. Ask which date starts it, whether a replacement resets the clock, and what happens if the role changes scope inside the window.

Their Job Ends at Signature

For a foreign national, the search is the short part. The rest runs on a sequence nobody owns unless the contract says so.

1. The employer registers on the foreigner work permit system and files the contract, an authenticated degree, a notarised criminal record certificate, a medical examination and evidence of relevant experience.
2. The permit notice takes 15 working days.
3. The candidate applies for a Z visa abroad and enters.
4. A work-type residence permit is filed within 30 days of arrival, a further 15 working days.
5. Social insurance registration adds about 10 days.

None of that is the recruiter’s legal responsibility, which is the point. The engagement ends at signature. The permit application belongs to the employer named on the contract, or to whoever it has engaged to run it — for a company without an entity in China, usually an employer of record under a separate agreement.

This is where cross-border hiring fails quietly. A German firm that has decided to substitute local hires on salary cost, as two thirds report doing, still needs a work permit for the one expatriate it keeps, and about a quarter of German companies in China have dropped such a hire because of visa processing. The visa itself is rarely the obstacle. The sequence behind it is.

Timing compounds it. Thirty-seven per cent of mainland employers shortened their hiring cycles in 2026 and 20 per cent found them longer, according to ManpowerGroup’s fourth-quarter survey, with internal approval delays among the five causes named. A permit that starts only after signature sits at the far end of that chain. The useful question at the pitch is what your clock assumes has already happened.

The German Chamber’s labour market survey explains why the clock binds. Technical sales and R&D have topped its hardest-to-fill list for several years, at least a third of members name them as the single hardest, and the cycle has lengthened by 30 per cent against five years ago. A function that already takes a third longer than it did has no room for a permit sequence that starts at signature.

A Firm That Never Says No Is Not Screening

Ask what the firm refuses. A search partner with a view of its own market turns work down: roles below a threshold where job boards would fill them anyway, twenty hires in a fortnight, a requisition whose reporting line is still undecided. Each refusal costs it revenue and tells you how it prices its own time.

ManpowerGroup’s engineer outlook puts the same problem from the other side: 73 per cent of employers say they struggle to fill high-skill engineering roles, and 42 per cent of manufacturing employees say they would consider leaving within six months. A firm promising to fill the role answers only the first number. The second is why a placement collapses inside the guarantee period, and it is a question about retention that a search firm is rarely asked and rarely volunteers an answer to.

In a market of 74,000 institutions, the capacity to say yes is not scarce. What is scarce is the judgement to say that 30,000 yuan a month will not move a process engineer with eight years inside a tier-one automotive supplier, and that the choice is either to pay for the grade above or to hire for potential. That sentence costs the firm the placement it was hired to make.

For foreign employers there is a second version. A partner that will not say the job description is wrong is protecting the fee rather than the relationship. The description written in head office assumes a grade, a reporting line and a set of responsibilities that may not exist in a Chinese organisation of forty people, and a recruiter who stays quiet about it will spend three months proving it slowly.

If This Is Your First Hire in China

Everything above assumes a legal entity, a payroll and somebody who can sign a contract. Without them the order changes. The first question stops being which search firm and becomes who the employer is on paper, because an agency cannot issue a contract on your behalf and a permit application needs an employer already in the system.

Two structures cover most first hires. A wholly foreign-owned enterprise takes months rather than weeks to register, needs registered capital and a leased commercial address, and once running handles its own contracts and payroll. An employer of record is a licensed local company that employs the person for you on a much shorter timeline while you direct the work. The trade is control and cost: an employer of record adds a monthly margin to every salary, and the employment relationship sits with a party chosen for convenience.

Whichever you pick, the search firm and the employing entity are two contracts with two parties. A recruiter who cannot say which one carries the permit filing has not thought about the part you are buying. Asking early is cheaper than finding the gap in the week an offer is accepted and a start date promised to someone about to resign.

Where this stops

Three limits worth stating. The fee conventions here are practice, not published tariff, and they move by city and by function. The permit timelines are the published service standards, which assume a complete file; a missing notarisation adds a month. And nothing here covers labour dispatch, which sits under a different licence and a different set of obligations.

One more thing sits outside the scope: what the market actually pays. A search firm will tell you a band once it has a candidate in hand, and by then the band is a negotiation rather than a benchmark. If you need the number before you brief anyone, that is a different piece of work, and worth doing first.

The order matters more than it looks. A band agreed after the shortlist is a band negotiated against three CVs and a start date. A band agreed before the brief is a filter, and it either confirms your range or tells you that the role you wrote is not the role the market pays for. Most of the searches we are asked to rescue went to market without that number, and the failure was decided in week one.

Which brings this back to the hour you spend choosing. After signature, the terms belong to the contract.

Sources

Ministry of Human Resources and Social Security, Provisions on the Administration of Human Resources Service Institutions, Order No. 50, effective 1 August 2023, articles 5 to 7.

State Council, Interim Regulations on the Human Resources Market, effective 1 October 2018, articles 18 to 21.

Ministry of Personnel, Ministry of Commerce and SAIC, Interim Provisions on the Administration of Foreign-Invested Talent Intermediary Agencies, third revision 2019.

Ministry of Human Resources and Social Security, national human resources service statistics for 2024 and the notice on integration pilot cities for human resources services and manufacturing.

Provincial and municipal government service guides for the foreigner work permit and work-type residence permit process, 2026.

ManpowerGroup, Employment Outlook Survey for the fourth quarter of 2026 and Global Engineer Outlook 2026. German Chamber of Commerce, labour market and salary report 2025-2026. Liepin, senior recruitment cycle data.

SunTzu Recruit

SunTzu Recruit runs specialist search for multinational employers building engineering and commercial teams in China, and for Chinese firms taking those teams abroad. We have worked the manufacturing, industrial and semiconductor tracks long enough to know which questions a search partner can answer from memory and which ones it fills in after the meeting. If you are choosing a partner in China, or inheriting one, talk to us before the contract is signed rather than after.

More of our reading on hiring into and out of China is on the SunTzu Recruit news page.