🇨🇳 Registry1 Nov 2024
China requires companies to file beneficial owner information
China's Measures for the Administration of Beneficial Owner Information, issued by the People's Bank of China and the State Administration for Market Regulation, took effect on 1 November 2024. Companies, partnerships and branches of foreign companies must file their beneficial owners through the company registration system. New entities file on registration, existing entities had until 1 November 2025, and changes must be filed within 30 days.
The People's Bank of China (PBOC) and the State Administration for Market Regulation (SAMR) issued the measures on 29 April 2024. They took effect on 1 November 2024.
What changed
- Who files: companies, partnerships and branches of foreign companies. Individually owned businesses are excluded.
- Beneficial owner: an individual who directly or indirectly holds at least 25% of the equity, enjoys at least 25% of profits or votes, or exercises actual control. If no one qualifies, the person in charge of day-to-day management is named.
- Exemption: entities with registered capital of no more than RMB 10 million whose shareholders or partners are all individuals, and where no one else exercises control or benefits beyond their formal role.
- Deadlines: new entities file when registering. Entities registered before 1 November 2024 had to file by 1 November 2025. Changes must be filed within 30 days.
- Filing is made online through SAMR's registration system. The PBOC published reporting guidelines on 28 October 2024.
What to do
Check that each Chinese entity has filed and that its filing is updated within 30 days of any ownership change.