the Ministry of Education issued the Notice on Resolutely Investigating and Punishing Covert Violations of Discipline-Oriented Off-Campus Training (hereinafter referred to as the Notice), emphasizing the determination to investigate and punish covert violations of discipline-oriented off-campus training. Since the release of the "Double Reduction" policy, local authorities have vigorously promoted the governance of off-campus training. However, some areas have seen training institutions move from overt operations to covert ones, changing their names to "high-end domestic services," "crowdfunding private tutoring," "study tours," and other terms to illegally conduct discipline-oriented off-campus training. These covert and variant practices seriously disrupt the enforcement of policies and hinder the progress of reforms.

1. How to Define Covert Violations of Discipline-Oriented Training?

According to the relevant introduction by the Department of Off-Campus Education and Training Supervision of the Ministry of Education, the Notice delineates the boundaries between compliant training behaviors and covert violations of discipline-oriented training from both positive and negative perspectives. First, the Notice emphasizes that conducting discipline-oriented off-campus training must comply with national regulations in terms of the training entity, personnel, time, location, content, and methods. Second, the Notice lists seven specific forms of covert and variant behaviors in contrast to the aforementioned compliance standards, including:

• Institutions or individuals without proper licenses or credentials conducting discipline-oriented training under the guise of consulting, cultural dissemination, "domestic services," "live-in tutors," "crowdfunding private tutoring," etc.
• Individuals without teaching qualifications or in-service middle and primary school teachers conducting illegal discipline-oriented training or offering paid tutoring.
• Conducting discipline-oriented training through methods such as "live streaming turned into recorded broadcasts."
• Organizing training sessions in locations such as residential buildings, hotels, and cafes, breaking down large groups into smaller ones to conduct "one-on-one" or "one-to-many" discipline-oriented training outside registered venues.
• Conducting discipline-oriented training under the pretense of study tours, research trips, summer camps, thinking skills, traditional Chinese culture, or integrating such training into non-discipline-oriented subjects like science, sports, and cultural arts.
• Offline institutions conducting illegal online discipline-oriented training through instant messaging, web conferencing, live streaming platforms, or online training institutions conducting illegal offline discipline-oriented training.
• Other covert and variant forms of discipline-oriented training that violate relevant regulations, serving as a catch-all category beyond the six listed forms.

2. How to Govern Covert Violations of Discipline-Oriented Training?

The relevant introduction by the Department of Off-Campus Education and Training Supervision of the Ministry of Education notes that governing covert violations of discipline-oriented training presents several challenges. First, covert and variant behaviors are highly concealed and adaptable, making them difficult to identify, requiring clear mechanisms for recognizing violations. Second, evidence for such behaviors is hard to preserve and involves multiple regulatory bodies, making it difficult to enforce penalties, necessitating clear identification of responsible entities. Third, covert and variant training is scattered and unorganized, with limited sources of information, making it difficult to regulate, requiring effective regulatory measures.

3. What Measures Are Being Taken?

For leads on covert violations of discipline-oriented training, the Ministry of Education will promptly coordinate and urge relevant local authorities to conduct investigations and report the results of the verification and handling. Local authorities are required to investigate, punish, and publicize any instances of covert and variant training as they are discovered.

To address the issue of covert and variant illegal training, the Notice emphasizes the establishment of a long-term mechanism and proposes three specific measures. First, establish a differentiation mechanism to clarify what constitutes a violation. Local authorities can form expert committees or designate professional institutions to scientifically differentiate covert and variant training behaviors. Second, implement local management to clarify who is responsible for enforcement. The principle of "who approves, who is responsible" will be enforced, with local authorities responsible for investigating covert and variant issues in discipline-oriented training. For unlicensed or unregistered institutions and individuals, penalties will be imposed according to the State Council's Measures for the Investigation and Punishment of Unlicensed and Unregistered Operations and the Promotion Law of Private Education. For cross-regional violations, relevant departments in both the approval area and the area where the violation occurs will jointly investigate. Third, strengthen regulatory enforcement to clarify how violations will be addressed. Emphasis will be placed on enforcing management responsibilities, utilizing grid-based comprehensive governance systems for patrols, establishing complaint and reporting channels, increasing enforcement intensity, advancing "Internet + regulation," and exploring various regulatory methods, including credit penalties.