Reed Smith Client Alerts

Key takeaways

  • People's Bank of China (PBoC) and State Administration for Market Regulation jointly promulgated Administrative Measures for Beneficial Owner Information on 30 April 2024
  • The Administrative Measures have been implemented since 1 November 2024
  • They stipulate specific provisions on record-filing and management of beneficial owner information in China

Scope of application of the Measures

According to article 2 of the Administrative Measures for Beneficial Owner Information (the Administrative Measures or the Measures), companies, partnerships, and branches of foreign companies are currently the “record-filing subjects/entities” that should complete such filing.

Furthermore, article 3 of the Administrative Measures provides for conditional exemptions for entities with a smaller scale and a simple equity/partnership structure. For an entity with a registered capital of less than RMB 10 million and whose shareholders and partners are all natural persons, if there is no natural person other than a shareholder or partner who actually controls it or obtains profits or benefits from it, and there is no situation where control is exercised over it or profits or benefits are obtained from it by means other than equity or partnership interests, the entity can be exempted from filing the beneficial owner information after making a commitment.