The enactment of negative list of cross-border trade in services in Shanghai Pilot Free Trade Zone is aiming to achieve the goal of comprehensively deepening the reform and opening up program of China (Shanghai) Pilot Free Trade Zone and being one of the important measures in conforming to the rules of international trade in services. The scope of the negative list includes exception of national treatment, exception of market access and the requirement of local presence. The exception of market access not only includes the measures in pro forma, but also the measures in effect. There are both connections and differences between the requirement of local presence and commercial presence. It is necessary to clarify the boundary between cross-border trade in goods and cross-border trade in services. Miscellaneous provisions could be included in the list, but it should be cautious to apply it.