The China compliance calendar: a foreign-owned company’s year, window by window

A foreign-owned Chinese company keeps one fixed annual cycle and several longer clocks. The combined annual report (年报) is filed between 1 January and 30 June; corporate income tax is reconciled by 31 May; a registered trademark renews in the twelve months before its ten-year term ends. This calendar gives every window with the date it opens.

Most compliance advice quotes deadlines. A deadline is the wrong thing to diarise: by the time it arrives, the documents it needs are late. This page runs on opening dates instead, for the owner or manager of a foreign-owned limited company (有限责任公司) in China who wants the year in one place. The filings themselves, their contents and the penalty figures are set out in what a Chinese company files each year; this guide is the calendar around them.

What does the fixed annual cycle look like?

Four windows recur every year on statutory dates, and a fifth applies only to companies holding a telecom licence. Each is listed with the day it opens, because everything here can be filed early.

Window opens	Closes	What is filed	Set by
1 January	30 June	The combined annual report (年报): one filing on the publicity system carrying the market-regulation report, the foreign-investment report and the foreign-exchange equity data	Publicity Regulation, Article 8; FI Reporting Measures, Article 14; the combined-report notice⁠[1,2,3]
1 January	31 May	Corporate income tax annual reconciliation (汇算清缴) for the year just ended, financial report attached	Enterprise Income Tax Law, Article 54; STA reconciliation measures⁠[4,5]
1 March	30 June	Individual income tax annual reconciliation. This one belongs to resident individuals, not to the company; the company’s role is monthly withholding	Individual Income Tax Law, Article 11⁠[6]
Each month or quarter	15 days after it ends	Provisional corporate income tax, and VAT for a monthly or quarterly period. Nil returns are still returns	EIT Law, Article 54; VAT Law, Article 30⁠[4,7]
1 January (licence holders only)	31 March	The telecom licence annual report to the licence issuer, for any company holding a value-added telecom licence	MIIT licensing measures, Article 35⁠[8]
Year end	Per the articles of association	The annual financial report, prepared at each accounting year end, audited by an accounting firm in accordance with law, and sent to each shareholder within the period the company’s own articles set	Company Law, Articles 208 and 209⁠[9]

A company registered part-way through a year files its first annual report the following year, and the foreign-investment report follows the same rule.^⁠[1,2] Whether the audit is truly compulsory, and why the bank reviewing a dividend expects audited statements anyway, are covered in the filings answer. The appointment of the audit firm is a governance step in its own right, taken by the shareholders, the board or the supervisory organ as the articles allocate it (Company Law, Article 215).^⁠[9]

Why does 30 June matter twice?

Because it closes two things at once: the filing window and the correction window. The annual report can be corrected only until 30 June of the year it is filed (Article 12), so a report submitted in late June leaves days, not months, to fix an error.^⁠[1] File in the first quarter and the correction window is real.

Missing the window has a fast consequence: the regulator decides abnormal-operations listings (经营异常名录) within 10 working days after 30 June, and the listing is public.^⁠[11] A listing left uncorrected for two consecutive years, with the company unreachable at its registered address, is a ground for revoking the business licence (Article 18).^⁠[1] One thing this page should say plainly, because older advice still repeats it: the automatic escalation after three years on the list no longer exists. The 2024 revision of the regulation removed it, and the current serious-violations measure contains no time-based rule.^⁠[1,12]

The combined report also discharges the foreign-exchange side. Since the 2019 reporting year, the market-regulation, commerce and foreign-exchange annual reports have been one filing (多报合一).^⁠[3] SAFE’s own guidance says a foreign-invested company completes its annual equity registration by filing that one report between 1 January and 30 June.^⁠[13]

When does the trademark clock need attention?

A Chinese registration lasts 10 years from the date registration was approved, and each mark and class carries its own clock.^⁠[14] The renewal window opens 12 months before the expiry date on the register and closes on the expiry date itself; a 6-month grace period (宽展期) follows.^⁠[14] Renewing early costs nothing: each renewal runs 10 years from the day after the previous term ended, wherever in the window it was filed.^⁠[14]

Missing both windows is expensive in a way owners rarely expect. The registration is cancelled, a new application competes under first-to-file like any stranger’s (Article 31), and for one year from the cancellation the Trademark Office will not approve applications for identical or similar marks. The statute states no exception for the former owner.^⁠[14] Diarise the renewal at the window’s opening date, not the deadline.

The quieter clock is non-use. Once a mark has gone unused for three consecutive years, anyone may apply to cancel it (撤三).^⁠[14] The registrant then has 2 months from receiving the Office’s notice to produce evidence of use that predates the application.^⁠[15]

Two months is no time to build an archive, and the accepted excuses are a short list: force majeure, government policy restrictions, bankruptcy liquidation and other causes not attributable to the registrant. Ordinary commercial inactivity is not on it.^⁠[15] Use means the mark on goods, packaging or transaction documents, or in advertising and exhibitions, identifying the source.^⁠[14] So the archive to keep is dated invoices, contracts and packaging, per mark and class. How marks are lost to squatters in the first place is in the first-to-file answer, and the class strategy behind a filing is what our trademark service exists for.

Which licences expire when the business licence does not?

The business licence (营业执照) itself has no term: the items printed on it include no expiry date, and no provision gives it one or requires renewal.^⁠[16] The 营业期限 sometimes shown is the company’s own duration from its articles, a filed particular, and its expiry is a dissolution ground rather than a licence lapse (Company Law, Article 229).^⁠[9,16] What does expire is the sector permit sitting next to the licence, and each permit names its own window on its face.

Permit	Term	Renewal window
Food business licence(食品经营许可证)	5 years	Opens 90 working days before expiry, closes 15 working days before expiry, at the original issuing authority. Applying later means suspending food operations after expiry until re-approval⁠[17]
Value-added telecom licence(增值电信业务经营许可证)	5 years	The application must be lodged by 90 days before expiry; a late application, or a service never launched, is not renewed. The same licence carries the first-quarter annual report above⁠[8]

What clocks start only when something changes?

The windows above run on the calendar. A second family runs on events, and these are the ones a remote owner misses, because nothing recurs to remind anyone.

The event	The clock	Set by
A registered particular changes (name, domicile, capital, legal representative, scope)	Apply for change registration within 30 days of the resolution or change	Registration Regulation, Article 24⁠[18]
Capital, equity or licence information arises or changes	Self-publish on the publicity system within 20 working days	Publicity Regulation, Article 10; Order 784, Article 4⁠[1,19]
Reported foreign-investment information changes without a registration	Submit the change report within 20 working days	FI Reporting Measures, Article 11⁠[2]
The company renames or moves	File the trademark change recordal, for all registered marks at once; leaving it invites an order to correct and, uncorrected, revocation of the mark	Trademark Law, Articles 41 and 49; Implementing Regulations, Article 30⁠[14,15]
A trademark licence is granted	The licensor records it with the Trademark Office within the contract’s term; unrecorded, it cannot be asserted against a good-faith third party	Trademark Law, Article 43; Implementing Regulations, Article 69⁠[14,15]

The stale-address failure is the one that compounds: renewal correspondence and the 2-month 撤三 notice both go to the registered details, so a move that never reached the registers can silently cost a mark.^⁠[15]

What falls due once, on 30 June 2027?

The capital adjustment: the one deadline on this calendar that does not recur. A limited company registered on or before 30 June 2024 must, by 30 June 2027, bring any remaining contribution period that would still run beyond five years measured from 1 July 2027 inside five years, and record the new period in its articles.^⁠[19] The shareholders then pay within the adjusted period. The decree quotes no end date for that period, but the arithmetic gives one: five years from 1 July 2027 ends on 30 June 2032, so no adjusted schedule can run past it.^⁠[19]

Whether your company is caught, with two worked examples, is in the 2027 deadline answer. A company formed since 1 July 2024 is on the plain five-year rule from establishment (Company Law, Article 47).^⁠[9] The 2026 annual report’s window closes the same day.

Which “annual obligations” do not exist?

Two supposed deadlines circulate that no instrument imposes, and both cost money when an agent invoices for them. There is no annual bank-account inspection: the account-licensing regime was abolished in 2019, and what remains is the bank’s own periodic due diligence, a request under the account contract rather than a statutory company filing.^⁠[20] And there is no annual chop inspection or renewal; the chop is filed once, when it is carved. A yearly invoice for either is a question to ask, not a deadline to pay.

What changes on 1 January 2027?

The revised Trademark Law, adopted 26 June 2026, takes effect. The clocks on this page survive it, but the article numbers above change: renewal moves from Article 40 to Article 44, and non-use cancellation from Article 49 to Article 57.^⁠[21] Non-use exposure also widens, because the authority gains the power to cancel an unused mark of its own motion, where today someone must apply.^⁠[21] An evidence archive that exists before that date is worth more after it. This page is re-checked on a 60-day cycle and will be updated against the new numbering when it lands.

How do you run this calendar from abroad?

Three habits cover most of it. Anchor every date to a document rather than to memory: the register entry for the trademark, the permit’s own face for its window, the articles for the capital schedule. Ask the firm that keeps the books for the adjusted tax calendar each January, because the holiday rule moves the 15-day windows most years.^⁠[10] And after 30 June, check the public record yourself. The publicity system shows whether the report was filed and whether the company is listed as abnormal, a check that needs no password and no accountant.

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