China can't run Windows 11 because foreign TPM chips are banned

Surface Laptop 4 Amd 2021 Keyboard Lights
Surface Laptop 4 Amd 2021 Keyboard Lights (Image credit: Daniel Rubino / Windows Central)

What you need to know

  • Windows 11 is now generally available, though many are having a hard time upgrading due to the operating system's CPU and TPM requirements.
  • Those TPM requirements are an even bigger barrier for Chinese consumers.
  • Because foreign TPM chips are banned in China, many Chinese PC users cannot upgrade to Windows 11.

Microsoft is a company with a global reach, and it depends on that reach to maintain its business. As such, it's unlikely that the tech giant didn't know about China's TPM restrictions. The question then becomes, why have said restrictions not been fully addressed and accounted for on day one?

While the answer to that remains unknown, what is known is that China is not having an easy go with upgrading to Windows 11, primarily because foreign TPM chips are banned in the country and those chips are part of the requirements for Microsoft's latest OS.

According to William Li, a semiconductor analyst at Counterpoint Research, Microsoft is tactically skirting TPM requirement rules in certain cases (read: Chinese and Russian exceptions) (via South China Morning Post). But those exceptions are happening at a higher level than the average consumer, at least right now. Many Chinese consumers are stuck at a crossroads because their hardware doesn't have the green light for Windows 11 and they have no way to get the necessary TPM tech.

The country's policy on TPM goes all the way back to 1999 as part of the long-running chipmaking war between the U.S. and China. China has opted for its own TPM equivalent rather than foreign variants (like the kind Microsoft is mandating for Windows 11). It goes with TCM, which stands for Trusted Cryptography Module.

Robert Carnevale

Robert Carnevale is the News Editor for Windows Central. He's a big fan of Kinect (it lives on in his heart), Sonic the Hedgehog, and the legendary intersection of those two titans, Sonic Free Riders. He is the author of Cold War 2395. Have a useful tip? Send it to

  • Nonsens. Microsoft will bend over and make a Chinese version, probably with some additional "features" that the Chinese dictatorship asks for or simply allow Chinese spy-hardware in the end. Big tech and Hollywood are the biggest Cinese ass-kissers.
  • That's a huge market to loose for any company. If they don't accept to their regulations, they will lose the entire market just like Google and some Chinese company will create an alternative. BTW, if US/EU can impose region specific restrictions on software and hardware, China has every right to do that too.
  • I agree with both of you. China should be able to put any restrictions it wishes and Microsoft is free to build a China specific version of Windows 11. But the rest of the world needs to be protected from a TCM with Chinese mandated backdoors. Maybe some sort of reverse geo-fencing to keep them from directly connecting to networks outside of China.
  • If this isn't an endorsement of TPMs' effectiveness and the correctness of Microsoft's decision to require them, then I don't know what is. It sounds like it's a simple fix to enable support for Chinese made TCMs, but this should theoretically help reduce security threats for both the US and China.
  • Yeah, and I'm surprised that Microsoft hasn't accounted for TCM support for China-only variant of Windows 11. Considering as a company, that's a pretty big market to miss out. Either there is a lot of behind-the-doors complications and legalities to address, which may be it is, or this TPM requirement is fairly late to be decided as a hard requirement for Windows 11 that Microsoft didn't have time to address this, thus why some earlier confusing messages on other hardware requirements for Windows 11 until only recently.
  • Then there is the third option: Most Windows installations in China are from pirated versions. This has been a huge problem in the past. The Chinese government and many others primarily use a version of Linux the government has modified (ahem - installed spyware on) and approved. I'd really like to see some numbers about how many legal installs of Windows there actually are in China.
  • The "N" release will be TPM'less and like always the American people will be taken in the pooper. Govt/Corp. all in the same business "Slavery"