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With the November 1, 2025 deadline fast approaching, businesses in China must act quickly to comply with the country’s new beneficial owner information (BOI) filing requirements.
Introduced by the People’s Bank of China (PBOC) and the State Administration for Market Regulation (SAMR), these measures took effect on November 1, 2024, and apply to most business entities, excluding individually owned businesses. Here’s what you need to know:
What types of businesses must comply?
The BOI Measures mandate that companies, partnerships, and branches of foreign companies registered in China must file beneficial owner information.
While beneficial owner information will not be publicly accessible, it will be available to relevant agencies for anti-money laundering and counter-terrorism financing checks.
Entities established before November 1, 2024, were granted a one-year grace period, which expires on November 1, 2025.
What is a Beneficial Owner (BO)?
A beneficial owner is defined as a natural person who ultimately owns or controls a registered entity or enjoys its ultimate benefits. This includes individuals who directly or indirectly hold 25% or more of the equity, shares, or partnership interests, or those who exercise actual control over the entity. If no such person exists, the individual responsible for daily operations and management is considered the beneficial owner.
While the concept of a beneficial owner may seem similar to that of an “actual controller” under China’s Company Law, there are important distinctions. A beneficial owner must always be a natural person, whereas an actual controller can be a legal entity. The beneficial owner definition also encompasses ownership, control, and income, requiring a deeper analysis to identify the ultimate individual behind the entity.
What are the consequences of non-compliance?
Non-compliance may result in fines up to RMB 50,000 (approximately EUR6,700) and potential disruptions to business registration or banking procedures.
What should my business do now?
New entities established after November 1, 2024, have to file beneficial owner information during the establishment registration process. If online filing is not possible, it can be completed on-site within 30 days of registration.
Existing entities must complete their filings by November 1, 2025, to avoid penalties. Only a few days remaining until the grace period expires, businesses should prioritize reviewing their ownership structures, collecting the necessary personal information, and ensuring data accuracy in the filing system.
Need assistance?
If your business has not yet completed its BOI filing, now is the time to act to avoid penalties and ensure smooth business operations.
Navigating these requirements can be complex, but you don’t have to do it alone. We are here to assist you with identifying your beneficial owners, preparing the necessary documentation, and ensuring your filing is completed accurately and on time. Reach out today (contact@orbis-alliance.com) to ensure your business remains compliant and avoids unnecessary risks.