Registration is getting harder to pass: four new checks in the last year

01Four checks, read as one timeline

• Stronger registration verification (proposed late 2025): additional verification requirements on the information filed at registration.
• Source-of-funds verification on shareholder contributions (effective early 2026): verification of where the money for the shareholding came from. This is the one that bears most directly on Chinese-invested companies — who actually paid, and whether the path can be explained, becomes a question at registration rather than one raised long afterwards.
• Scrutiny of changes to authorised signatories (effective mid-2026): the signatory is the direct expression of who can bind the company. Bringing changes under scrutiny means control arrangements have entered the field of view.
• Mandatory online registration (from mid-2026): the process moves online.

Read together the direction is consistent: source of funds, signatory structure, and an online record. All three point at the same thing — establishing who actually put up the money and who actually decides. That is exactly where a nominee structure is least able to withstand examination.

02What it means for Chinese-invested companies

None of these checks target foreign investors specifically. Their combined effect, however, falls hardest on the way Chinese-invested companies have typically been set up:

• The funding path has to be planned in advance, not explained afterwards. Whether the money comes from the offshore parent or a personal account, and whether it passed through a third party, has to be stated and evidenced at registration.
• "Register the company first and adjust the shareholding later" has become riskier. Changes to signatories and shareholders are themselves under scrutiny; later adjustment is no longer a formality.
• Mandatory online filing means a record. Every registration and every change sits in the system, which makes inconsistency between them easier to see.

03What is being squeezed alongside it

Detection of nominee-type arrangements is being strengthened in parallel. One of the markers is a mismatch between the registered shareholder and the actual contribution and control — the money was not his, the decisions are not his, the returns do not go to him. Source-of-funds verification enters from the hardest end of that: the money.

Note also that this kind of detection does not only happen at the moment of registration — later changes, annual filings and other steps can trigger it. "Nobody asked at the time" is not the same as the matter having been settled.

04How to prepare if you are setting up now

Everything below is cheap to do before registration and expensive to fix afterwards:

• Settle the structure, then register. Whether the business falls in the restricted schedules, whether to take the promotion route, how control is to be arranged — decide these before registration rather than adjusting afterwards.
• Assemble the contribution evidence chain in advance: source of funds, remittance path, and how they correspond to the shareholder.
• Settle the signatory arrangement once: who may bind the company, sole or joint signature. This is a governance question as much as a verification one.
• Do not use a nominee to "get the company open". Under the current direction of verification, that buries the risk at the foundation.