Financial Crime World

Beneficial Owner Filing System in China: Key Requirements and Procedures

The Chinese government has established a beneficial owner filing system as part of its 2024 BOI (Business Operation Administrative Measures). This article provides an overview of the key points, including registration deadlines, exemptions, information to be filed, management of the filing system, accessibility of recorded data, and future developments.

Registration Date

  • The deadline for existing entities to file beneficial owner information was November 1, 2025.

Exemption for Small Entities

  • Entities with a registered capital not exceeding RMB 10 million and where all shareholders or partners are natural persons can be exempt from filing beneficial ownership information.

Change of BOI Filing

  • If there’s any change to beneficial owner information or if the entity no longer qualifies for exemption, updated information must be filed within 30 days through the relevant registration system.

Information to be Filed

When filing beneficial owner information, a filing entity is required to provide:

Details of Beneficial Owner

  • Name
  • Gender
  • Nationality
  • Date of birth
  • Address of habitual residence or workplace
  • Contact details
  • Type, number, and period of validity of the identity certificate or other identity documents

Beneficial Ownership Relationship

  • Type of the beneficial ownership relationship, date of formation, and termination (if any)
  • The ratio of equity, shares, or partnership interests held by the beneficiary owner (depending on the specific situation)

Management of Beneficial Owner Filing System

The SAMR will coordinate and guide the development of the relevant registration system. Local market regulatory authorities at the county level or above will supervise filing entities to ensure they promptly file beneficial owner information.

Accessibility of Recorded Data

The recorded data will not be publicly disclosed but will be accessible only to government departments and anti-money laundering obligated institutions for fulfilling their legal duties.

Future Developments

  • For most filing entities, the beneficial owner is the individual who ultimately holds more than 25 percent of the shares.
  • Only filing entities with complex ownership arrangements need to identify beneficial owners according to the standards specified in the 2024 BOI Measures.
  • The PBOC will issue a “Beneficial Ownership Information Filing Guide” to provide guidance for their filing work.