In recent years, China has widely adopted the blacklist system, a concept originated from British education to penalize student misconduct, in its administrative management. This adoption comes amid reforms to the administrative approval system, emergency response, and efforts to build a trustworthy society. While the administrative blacklist system positively enhances government risk prevention and strengthens law enforcement coordination, it can adversely affect the rights and interests of those blacklisted. A crucial question emerges: Can individuals who believe their blacklisting infringes upon their legitimate rights and interests initiate administrative litigation to hold the responsible agency and officials accountable for unlawful actions? This problem depends on the nature of administrative blacklist system. From the perspective of positive law, the administrative blacklist system has six internal structures: a single blacklist model, blacklist and disclosure model, blacklist and direct disciplinary model, blacklist and indirect disciplinary model, blacklist and combined disciplinary model and blacklist and independent disciplinary model. It also has three external effect realization structures: realization of effect based on blacklist act itself, realization of effect based on disciplinary act directly triggered by blacklist and realization of effect based on disciplinary act indirectly added by blacklist. Determining the justiciability of administrative blacklisting actions requires first assessing whether they fall within the purview of the Administrative Procedure Law. For blacklisting actions not explicitly covered by the law, a substantive evaluation must be made to determine if they have no practical impact on the rights and interests of the affected party. Specifically, a single blacklist model, which has no external effect, belongs to the internal administrative act and cannot be sued. The blacklist and disclosure model, which can produces factual influence to counterpart' rights, can be sued. The blacklists in blacklist and indirect disciplinary model and blacklist and combined disciplinary model belong to the fact elements of subsequent disciplinary acts, which can be sued after being separately disclosed and only have the adjunctive justiciability when prosecuting disciplinary acts if not separately disclosed. In today's complex social landscape, where natural hazards and self-reflexive risks intersect, administrative agencies autonomously develop and implement innovative regulatory tools. This innovation is driven by practical law enforcement needs, technological progress, and reform imperatives. For these new credit regulation instruments used in intricate administrative affairs, it is crucial to first establish their de facto status and then design a tailored legal framework to govern them. Only through this approach can regulatory tools, exemplified by administrative blacklists, fulfill their intended functions within the boundaries of the rule of law.