上有政策，下有对策: “There are policies above, and countermeasures below.”
Xi Jinping has drawn a line against it. Leading officials, and above all the “number ones” of Party and government, he said, must “never be allowed to practice ‘policies above, countermeasures below,’ and still less selective implementation.” People’s Daily quoted the sentence in June 2026.
In a study titled “The Phenomenon of Collusion Among Grassroots Governments,” the sociologist Zhou Xueguang describes how local governments deal with the policies and inspections of their superiors. They use all kinds of means of “policies above, countermeasures below.” Collusion among grassroots governments, he writes, has become “an institutionalized form of informal behavior.”
Zhou also notes that some of these practices have been “an important source of institutional innovation.”
走过场 To cross the stage. In Chinese opera, a role that enters and leaves at once. Figuratively, to do something only for the form.
钻空子 To drill into the gap. To use a loophole or an opening.
打擦边球 To hit an edge ball, as in table tennis. To bend the rules. In 2025, the Party’s website quoted Xi Jinping: “Many leading officials start by hitting edge balls, breaking the Eight-point Regulation, and in the end it becomes a big problem.”
土政策 A homemade policy. Rules and decisions that a locality, office or enterprise makes on its own.
From June 1, 2008, a State Council rule banned the production, sale and use of shopping bags thinner than 0.025 millimeters, and shops had to charge for bags.
In 2016, an official of the National Development and Reform Commission reported that bag use in supermarkets and malls had generally fallen by more than two-thirds. The official also named the problems: enforcement in farmers’ markets was hard, the public’s understanding differed, and substitutes cost more. Reporters found compliant bags hard to find in the markets.
Homes built on village collective land and sold to outsiders are called xiao chanquan fang, “minor property rights housing.” In June 2007, the Ministry of Construction warned city residents not to buy houses built on collective land. In January 2008, a State Council notice said that city residents “may not buy” rural homesteads, farmers’ houses or minor property rights housing.
The bans kept coming. Two ministries issued another notice in August 2012. In November 2013, an urgent notice ordered all such projects under construction or for sale to be stopped. In 2017, Beijing ruled that rental housing on collective land was “for rent only, not for sale,” to stop “minor property rights housing in disguise.”
On December 4, 2012, a Politburo meeting considered the Eight-point Regulation on the conduct of officials, put forward by Xi Jinping. Discipline officials later reported “hidden variants” (yinxing bianyi). Banquets went “underground, from the open into the dark,” to private clubs and company canteens. Gifts came as lecture or consulting fees and as electronic gift cards.
In 2017, the Central Commission for Discipline Inspection issued a set of WeChat stickers about the regulation. One read: “No entering private clubs.”
In March 2019, the General Office of the Central Committee declared 2019 the “year of reducing burdens at the grassroots.” Its notice targeted inspections and evaluations that were “too many and too frequent,” and guodu liuhen, “excessive leaving of traces,” the record-keeping done to prove that work was done.
One rule was specific. Screenshots of work scenes or videos uploaded to WeChat work groups and government apps may not replace an assessment of the actual work.
In July 2021, the “double reduction” policy forced tutoring companies for school subjects to become non-profit organizations. A year after the policy, many small tutoring businesses had moved underground.
On December 13, 2022, the Ministry of Education and eleven other departments issued an opinion against “hidden and variant” subject tutoring. Recruitment and tutoring websites were barred from posting tutoring jobs, and advertising tutoring to primary and middle school students was banned.
In 2019, media reported that mines of Shandong Changsheng Mining in Xintai, Shandong, had painted the rocks around a stone-processing plant green. According to the reports, the aim was to get through environmental inspections and to deceive satellite monitoring.
Article 51 of the Communist Party’s Regulations on Disciplinary Action, in their 2018 version, punishes members who are disloyal and dishonest toward the Party, “are one thing outside and another inside, comply in public and defy in secret, and deceive those above and below.” The Party calls such a member a 两面人, a two-faced person.
In January 2026, Xi Jinping described such people to the Central Commission for Discipline Inspection. Some, he said, “state their position very quickly and in a very high key” on carrying out the Party’s major decisions, “but in fact comply in public and defy in secret.”