Do I have to have a tour guide to start a travel agency?

Article 28 (4) of the Tourism Law stipulates that the establishment of travel agencies must have necessary tour guides. This is a new regulation clearly put forward by the Tourism Law. This is a legal provision to protect the legitimate rights and interests of tour guides, but also to ensure the operation of travel agencies. Compared with the Travel Agency Regulations, this provision is a highlight of the Tourism Law.

According to Article 2 of the Regulations on the Administration of Tour Guides, a tour guide refers to a person who has obtained a tour guide certificate and accepted the appointment of a travel agency to provide guidance, explanation and related travel services for tourists. It can be seen that tourists do not refer to those who are in the first-line tour guide positions. So the "tour guide" here can be understood as a person holding a tour guide card.