Chinese Social Credit Blacklists: A Trove of Public Data Hiding in Plain Sight

Official Chinese policy documents claim that the social credit system is meant to improve corporate compliance. The “system” consists of hundreds of disparate scores, blacklists, and redlists, which various government departments and agencies use as tools for punishment and reward.

Companies can land on blacklists for engaging in “non-trustworthy” behavior, which can range from tax fraud, contraband distribution, use of fraudulent documents, or failure to comply with registration requirements. The government often restricts blacklisted companies from applying for permits, project approvals, and more.

The Chinese government intentionally makes blacklists public in order to improve trust and credibility in China’s business environment. Unlike legal databases or court documents in other jurisdictions, social credit blacklist databases are searchable and rich with unique identifiers and related parties. The blacklists can provide investigators with insights into corporate risk that is otherwise unavailable in publicly available information.

With that being said, analysts should always attempt to corroborate information from blacklists with other sources and hedge claims accordingly.

The Chinese government’s efforts to consolidate and streamline corporate data collection led to the development of the National Enterprise Credit Information Publicity System (NECIPS). The Chinese government intends for NECIPS to include information on a company’s blacklisting status. However, in practice, not all blacklist information is available on NECIPS records — lists outside of NECIPS can provide more detailed information on a company’s blacklist status.

Many of the hundreds of social credit blacklists are publicly available. However, their format and user-friendliness can vary. For instance, the State Council’s aggregation of blacklisted companies across China, while comprehensive, does not allow readers to easily search company names or ID numbers. Other blacklists, such as the Labor Remunerations Defaulting blacklist, are structured as a list of text documents with dates; still others are user-friendly searchable databases, such as the Import/Export Social Credit Blacklist. Many blacklists provide legal representatives, which analysts can use as jumping-off points for further investigation.

The central government’s National Court Defaulter Blacklist contains the names and redacted ID numbers of corporations and individuals who have failed to comply with court orders (most of the infractions involve failure to make court-ordered payments). Users can search by company/individual name, Unified Social Credit Code, and can filter results by province. The database provides detailed information on entities, the amount and number of payments that an entity has failed to make, as well as the names of related parties on the relevant court case.

China’s General Administration of Customs blacklists companies for cross-border smuggling, failure to update registration or pay taxes on time, or breaking a number of other customs laws. Blacklisted companies appear on the Import/Export Social Credit Blacklist, but the list does not specify why each entity was put on the blacklist in the first place. Nonetheless, a company’s presence on the blacklist signifies its poor standing with Chinese regulators. Doing business with blacklisted importers or exporters could lead to reputational or regulatory backlash.

Outside of media reports, it’s difficult to ascertain whether a Chinese entity is engaged in labor violations. The central government’s Department of Human Resources and Social Security publishes a blacklist of companies who have defaulted on wage payments for their workers.

Withholding of wages is a serious violation that falls under the United Nations’ International Labor Organization indicators of forced labor. The list provides the legal name, address, Unified Social Credit Code, legal representative, the amount of wages the company owes, and a note on whether the company is under investigation.

It is important to note that while the list provides detailed information on companies that have violated labor remunerations policies, it is far from a comprehensive list of Chinese companies that employ forced labor.