Key Requirements and Compliance Guidance of Beneficial Ownership Information Filing for Entities in Mainland China

• Companies, partnerships, and foreign companies’ branch offices in Mainland China are required to file their beneficial ownership information with the local Administration for Market Regulation authorities
• A beneficial owner refers to an individual who holds 25% or more equity interests; is entitled to 25% or more capital proceeds or voting rights; exercises de facto control; or is responsible for the day-to-day management of an entity
• Newly established entities must complete the required filing within 30 days of establishment; the November 1, 2025 deadline for existing entities to complete their filings has been extended with the new deadline yet to be specified by the competent authorities
• Failure to follow the new filing requirement or submission of inaccurate beneficial ownership information may result in correction orders, fines of up to RMB 50,000, and other legal consequences
• Businesses are advised to conduct a self-assessment, identify beneficial owners, and confirm the local requirements to fulfill the Filing Requirement and mitigate compliance risks

Regulation of Beneficial Ownership Information Filing for Entities in Mainland China