The Measures came into effect on November 1, 2024, and all existing registered entities must complete the filing of beneficial ownership information by November 1, 2025.

• Companies;

• Partnerships;

• Branches of foreign companies;

• Other entities as designated by the PBOC and SAMR.

Individual industrial and commercial households are exempt from filing.

Non-corporate legal persons, sole proprietorships, farmers’ cooperatives (and federations), as well as branches of domestic companies or partnerships are temporarily not required to file.

Enterprises with registered capital of RMB 10 million or less, whose shareholders or partners are natural persons, may be exempted from filing upon declaration, provided there are no other individuals who ultimately control or benefit from the entity.

A “beneficial owner” refers to a natural person who ultimately owns, controls, or benefits from the entity. The criteria include:

1. Directly or indirectly owning more than 25% of the entity’s equity, shares, or partnership interests;

2. Enjoying more than 25% of the entity’s economic benefits or voting rights, even if not meeting the ownership threshold;

3. Exercising ultimate control over the entity, individually or jointly, through agreements, relationships, or other means.

If no such individual can be identified, the person responsible for the entity’s daily management shall be considered the beneficial owner.

For wholly state-owned or state-controlled companies, the legal representative must be filed as the beneficial owner.

For branches of foreign companies, the beneficial owners include both the beneficial owners of the parent company (as determined under these Measures) and at least one senior executive of the branch, such as the branch manager. Foreign companies and their branches are not eligible for the declaration-based exemption.

Example: How to Identify Beneficial Owners When Both Individual and Corporate Shareholders Exist?

 

For example, Company A (as depicted in the chart) has two shareholders: Individual X (30%) and Company B (70%). Company B’s shareholders are Individuals Y (30%), Z (20%), and W (50%). Individuals Z and W are also shareholders of Company C, holding 50% each. Their effective ownership in Company A is as follows:

 

1. X directly owns 30% of Company A;

2. Y indirectly owns 21% (30%×70%);

3. Z indirectly owns 31.5% (50%×50%×70% +20%×70%);

4. W indirectly owns 17.5% (50%×50%×70%).

Ownership Structure Chart of Company A

 

Therefore, Individuals X and Z, who ultimately own over 25% of Company A, should be identified and filed as its beneficial owners.

 

Existing entities must complete filing by November 1, 2025. Any change in beneficial ownership or loss of exemption eligibility must be filed within 30 days of the change.

The following information must be reported:

1. Full name;

2. Gender;

3. Nationality;

4. Date of birth;

5. Usual residential or business address;

6. Contact details;

7. Type, number, and validity period of identification document;

8. Type of beneficial ownership relationship, with start and (if applicable) end dates.

For non-equity-based ownership relationships, the type and relevant dates must also be recorded.

• The SAMR oversees system development and filing guidance;

• The PBOC is responsible for information receipt, storage, verification, and management;

• Authorized agencies and financial institutions may access information lawfully for AML, CTF, and regulatory purposes. All obtained information must remain confidential.

Entities failing to file beneficial ownership information as required will be handled in accordance with relevant administrative regulations on business registration.

If the PBOC or its branches discover inaccuracies in filed information, they may order correction within a specified period; failure to do so may result in a fine of up to RMB 50,000.