On March 17, 2025, the director of the State Taxation Administration, signed Order No. 58, formally promulgating the “Interim Measures for the Administration of Tax-related Professional Services” (hereinafter referred to as the “Measures” or the “new regulations”).

The new regulation, to be implemented on May 1, signals the entry of China’s tax service industry into an era of full-cycle regulation. Previously, only the bookkeeping agency industry had strict norms, while tax intermediary services were largely unregulated, except for the 2017 “old regulations.” The new regulations, introduced as departmental rules (State Taxation Administration Order No. 58), have higher legal efficacy than the old ones (State Taxation Administration Announcement No. 13 of 2017), shifting supervision from flexible guidance to rigid constraints. This change strengthens the tax authorities’ law enforcement basis, with new violations in Article 31 that can be directly punished under departmental rules. The Measures upgrade industry supervision from paper norms to institutional reconstruction, foreshadowing a market shake-up in the trillion-yuan market.

I. Real-name System Management

The real-name system management system established in Article 3 of the Measures can be regarded as the “digital ID card” system for tax intermediaries.

All tax service personnel are required to complete real-name authentication through the electronic tax bureau, and the basic information of the institutions needs to be dynamically filed with the tax authorities.

In terms of technical details, the innovative “credit code” mechanism in Article 13 (in the form of a QR code to display the credit rating in real time) will transform the practitioners’ practice trajectory into a traceable data stream.

Article 10 implements administrative registration for tax consulting firms, which is essentially a supply-side reform. The registration conditions may include the number of certified personnel, registered capital, business premises, etc., which will eliminate a large number of “workshop-style intermediaries”. However, for cross-border institutions such as accounting firms and law firms, it has instead gained new market entry opportunities.

II. Service Classification Management

Article 7 of the Measures classifies tax services into eight major categories, and Article 8 further divides them into “general” and “specific” services, which is essentially a reconstruction of the industry value chain.

Basic business such as bookkeeping agency (Article 7, Item 1) has completely become a red ocean battlefield; while specific services such as tax compliance planning (Item 4) and cross-border tax attestation (Item 5), due to the administrative registration threshold set in Article 10, have become the exclusive battleground for leading institutions.

The proportion of high-end consulting income will increase, while traditional agency business will contract. If small and medium-sized institutions cannot complete service upgrades within two years, they may face market clearance.

III. Credit Grading System

Compared with the old regulations, a major breakthrough of the new regulations is the five-level credit evaluation system (TSC1-TSC5) clearly defined in Article 18, which is essentially the “invisible tax ticket” in market competition.

Institutions above TSC4 level can obtain government procurement orders with priority, while institutions below TSC2 level may face customer loss.

According to the reclassification of service categories in Article 7 of the Measures, the entry threshold for specific services (tax compliance planning, tax attestation, etc.) has been significantly increased.

The more far-reaching impact lies in the dynamic accumulation mechanism of credit points: practitioners can accumulate points for each compliant business they complete, but a major violation may lead to the clearance of points.

This “credit game rule” forces institutions to establish internal compliance point systems.

The credit display and repair system established in Article 19 also provides a “way to reform and return to the right path” for institutions that occasionally violate regulations.

IV. Cutting off the Gray Interest Chain

Article 5 of the Measures explicitly prohibits tax officials from interfering in the operation of intermediaries, directly targeting the three major chronic problems of the industry: rent-seeking in qualification approval, business direction, and information arbitrage.

The case of a tax official in a city in Hubei in 2024 manipulating the rating of a firm is a typical example of such gray transactions. After the implementation of the new regulations, similar behavior will face criminal liability under Article 397 of the “Criminal Law”.

For intermediary institutions, this means the end of the “relationship-based customer acquisition” model.

V. Full Collection of Business Information

The business information collection system established in Article 15 transforms tax services into analyzable data assets.

Specific services need to report complete business elements, which not only provides risk control basis for tax authorities, but also gives birth to a new data service market.

However, data security has become a new challenge.

Article 16 requires the electronic archiving of working papers to meet the reliability standards of the “Electronic Signature Law”, which poses a rigid requirement for the IT systems of institutions.

VI. Quality Backward Push Mechanism

The mandatory business record system in Article 16 requires the “signature + seal” dual confirmation of working papers.

This not only enhances the traceability of services, but also forces institutions to upgrade their internal control systems. The accompanying continuing education requirements will accelerate the talent reshuffling in the industry.

On the day following the promulgation of the Measures, March 18, the Central Commission for Discipline Inspection issued an article titled “Several Ministries and Central Enterprises Hold Meetings to Promote the Deepening of Anti-corruption in an Integrated Manner by Leading the System from the Top Level”, which clearly listed invoice management, export tax rebates, tax intermediaries and other seven fields as key areas for anti-corruption, forming a policy combination.

The tax field’s governance logic has clarified, from strong State Taxation Administration supervision to Central Commission for Discipline Inspection’s “big data anti-corruption” on tax intermediaries. The next two years will bring compliance challenges, pushing non-compliant institutions out of the market and likely increasing leading firms’ market share to over 30%. Tax intermediaries relying on gray areas will be exposed by regulatory networks, much like blockchain-locked fictitious invoices. From credit codes to ministerial meeting rectifications, each measure is rewriting the rules of the game for tax services, with professionalism emerging as the key to a brighter future for the industry.