In June 2015, a total of 64 transnational higher education institutions (TEIs) were approved by the Ministry of Education (MOE) to operate in China's higher education sector. The TEIs were established in two batches. The first batch of 24 TEIs resulted from a policy promulgated in 1995, whereas the second batch of 40 TEIs resulted from two regulations enacted in 2003 and 2004. The selection criteria used by the MOE to grant approval for the establishment of TEIs are not openly available. Thus, this study aims to identify the actual changes in policy between 1995 and 2003/2004, by analyzing the characteristics of the TEIs in the two batches. It was found that TEIs were more likely to be approved by the MOE in the second batch if (a) they cooperated with high-ranked European partners, (b) they were affiliated with a Chinese university rather than having legal person status, and (c) they offered programs in IT, science, or engineering.