On April 28, 2026, China’s Ministry of Culture and Tourism officially issued the Guidelines for Carbon Neutral Operations in Outbound Group Tour Services (Trial), putting forward, for the first time, systematic carbon emissions accounting and offset requirements for outbound tour operators. This policy directly affects travel agencies’ operational compliance assessments, especially AAA-rated travel agency review results, and warrants close attention from related niche segments such as outbound travel services, low-carbon consulting, and carbon asset development.

Event Overview

On April 28, 2026, China’s Ministry of Culture and Tourism issued the Guidelines for Carbon Neutral Operations in Outbound Group Tour Services (Trial). The document clearly requires outbound tour operators to conduct carbon emissions accounting for key service links such as flights, chartered vehicles, and accommodation, and encourages the use of domestic Certified Voluntary Emission Reduction (CCER) projects for carbon offsetting. Although this guidance is a trial version, it has already been included as a key item in the Ministry of Culture and Tourism’s annual compliance review of outbound travel agencies, and its implementation will directly affect AAA-rated travel agency review results.

Which Industry Segments Will Be Affected

Outbound Tour Operators

As the entities directly subject to the policy, outbound tour operators must establish carbon emissions accounting mechanisms covering the entire service chain, including transportation, accommodation, and ground handling. The impact is mainly reflected in rising compliance costs, the need to restructure internal processes, higher standards for supplier management, and substantial risks in annual review results.

Carbon Accounting and Consulting Service Providers

Since the guidance explicitly requires carbon emissions accounting for flights, chartered vehicles, accommodation, and other service links, developers of carbon accounting tools with tourism scenario adaptation capabilities, third-party verification institutions, and low-carbon consulting service providers will gain business opportunities. The impact is reflected in a shift in service demand structure—from general carbon inventory services to tourism-specific methodological support and increased demand for practical training.

Domestic CCER Project Developers and Operators

The guidance encourages the use of domestic CCER projects for carbon offsetting, creating new application scenarios for CCER projects such as forestry carbon sinks, renewable energy, and methane recovery. The impact is mainly reflected in the need for project parties to strengthen their ability to connect with tourism enterprises, including developing tourism carbon offset product packages that are verifiable, traceable, and available for bulk procurement, rather than being designed only for industrial or power-sector users.

Overseas Hotels, Airlines, and Ground Service Providers

Although they are not directly regulated by the policy, as key parts of the outbound travel supply chain, the availability of their carbon emissions data, willingness to disclose, and certification qualifications will affect the completeness of tour operators’ accounting. The impact is reflected in the possibility that Chinese tour operators may add carbon data provision clauses to procurement agreements, driving overseas partners to passively participate in coordinated low-carbon management.

What Relevant Enterprises or Practitioners Should Focus On and How They Should Respond Now

Monitor the Release Schedule of Follow-up Explanatory Documents and Detailed Accounting Rules from the Ministry of Culture and Tourism

The current guidance is a trial version, and specific accounting methods, sources for emission factor values, and standards for recognizing CCER procurement have not yet been made public. Relevant enterprises should continue tracking notices on the official website of the Ministry of Culture and Tourism and provincial-level cultural and tourism authorities, with particular attention to whether operational manuals or compilations of pilot cases will be issued before the third quarter of 2026.

Sort Out High-Emission Service Links in Existing Outbound Routes and Start Baseline Estimation

Priority should be given to identifying routes involving high-frequency, long-haul flights (such as Europe-bound and U.S.-bound routes), concentrated stays in high-star hotels, and frequent intercity chartered vehicle use, and trial calculations should be carried out according to the scope listed in the guidance. The goal is not one-time precision, but to establish accounting logic and data collection pathways, leaving a response window for subsequent compliance reviews.

Distinguish Between Policy Signals and the Actual Pace of Business Implementation

This guidance is a “trial” document and does not stipulate penalties, so the current stage places greater emphasis on capability building rather than mandatory punishment. Enterprises should avoid signing long-term CCER procurement agreements too early or making heavy investments in developing proprietary carbon platforms. Instead, it is advisable to transition through a lightweight ledger management + third-party light consulting approach, and then make systematic investments after accounting standards stabilize.

Communicate in Advance with Key Overseas Suppliers on the Feasibility of Carbon Data Collaboration

For existing partners such as international hotel chains, major airlines, and mature destination management companies, non-binding communication can be initiated to understand the current status of their ESG report disclosures, the granularity of carbon data, and their willingness to share, thereby building a basis for future revisions to procurement clauses and reducing subsequent compliance friction costs.

Editorial Viewpoint / Industry Observation

Observably, this guidance functions primarily as a regulatory signal—not yet an enforcement tool. Its inclusion in AAA-level agency re-evaluation criteria elevates its operational weight beyond typical ‘guidance’ documents, but the absence of mandatory timelines, penalty provisions, or standardized calculation tools means real-world implementation remains phased and institutionally dependent. From an industry perspective, it marks the formal entry of carbon accountability into outbound tourism’s compliance architecture—a structural shift that will gradually reshape procurement logic, supplier evaluation metrics, and service packaging standards. Continuous monitoring is warranted not for immediate compliance pressure, but because it signals how climate-related obligations may cascade across travel value chains in coming years.

Conclusion
This guidance is not an immediately effective mandatory regulation, but rather a key starting point for building a carbon management mechanism in the cultural and tourism industry. Its real significance lies in formally incorporating carbon emissions into the core compliance framework of travel agencies, rather than treating them merely as a corporate social responsibility issue. At present, it is more appropriate to understand it as an act of “institutional track-laying”: it does not immediately change business models, but it has already begun to define the compliance baseline and new dimensions of competition for outbound tourism services over the next 3 years.

Information Source Notes
Main source: publicly available official document on the website of the Ministry of Culture and Tourism of the People’s Republic of China, Guidelines for Carbon Neutral Operations in Outbound Group Tour Services (Trial) (issued on April 28, 2026).
Areas requiring continued observation: whether the Ministry of Culture and Tourism will issue supporting detailed accounting rules, a list of pilot regions, and a recognized list for CCER procurement before the third quarter of 2026.