Sept. 2025 - Reminder - Beneficial owner report filing due 1 November 2025

Scope and identification criteria for beneficial owner(s)

Any natural person who meets one of the following criteria should be considered a “beneficial owner” of the entity and be subject to filing:

• Criterion 1: A natural person who ultimately owns 25% or more of the equity, shares or partnership interests of the filing entity, either directly or indirectly;
• Criterion 2: A natural person who, although not meeting Criterion 1, ultimately holds 25% or more of the profit rights or voting rights of the filing entity; or
• Criterion 3: A natural person who, although not meeting Criterion 1, exercises actual control over the filing entity, either alone or jointly with others.

Points of attention

• There may be multiple natural persons who qualify as beneficial owners, and any individual who meets any of the three criteria mentioned above should be identified and filed as a beneficial owner.
• In identifying beneficial owners, it is required to trace to the ultimate natural person who owns or controls the filing entity or enjoys its ultimate benefits.
• If there are no individuals who meet Criteria 1, 2, or 3, the person responsible for the daily operation and management should be considered as the beneficial owner, and at least one individual responsible for the highest level of daily operation and management should be filed. 
• The “person responsible for daily operation and management” may include the legal representative, directors and managers of the filing entity.

Due date

• Entities registered before 1 November 2024 must comply with the new requirements by 1 November 2025.
• The Company may be fined no more than CNY50,000 if the beneficial owner information is not submitted or is inaccurate and the necessary correction is not made within the stipulated period.

For more details, please see the related newsletter that we published in December 2024.

We understand that this is a time-consuming task, and to avoid any delays, we recommend starting the UBO filing process at the earliest convenience.

The Forvis Mazars Corporate Secretarial team would be happy to assist with the UBO filing, do not hesitate to reach out to us to assess your situation.

References:

People's Bank of China and the State Administration for Market Regulation, Decree [2024] No. 3: Administrative Measures on Beneficial Owner Information.