Eight things a China company registration quote leaves out
A China company registration quote usually covers name approval, the registration filing, the business licence and the chops. It usually leaves out the bank account, the filings needed to export in your own name, the licensed bookkeeper, the taxpayer status and the registered capital you commit to paying in within five years. Ask for the exclusions in writing.
Registration quotes are not usually dishonest. They are quotes for the filing, and the filing is the part that is easy to scope. The expensive surprises live in the steps that come after it, and in one commitment you make on the way in. A buyer reads “company registration” as “a working company”, and those are different finish lines.
Before any of this there is a prior question: whether you need a Chinese entity at all. If you only buy from or sell to China from abroad, you usually do not; see do you actually need a Chinese company?
What does a registration quote usually cover?
Name approval, preparation and lodgement of the registration documents, the business licence, and the set of company chops. That is a real piece of work and it is what most providers sell. How long it takes, and why the bank account is the step that runs longest, is set out in how long it takes to register a company in China.
What are the eight things it usually leaves out?
The eight below. Each is a step or a commitment that a working company needs and a filing quote does not have to include.
1. The registered address, and the paperwork behind it
The address is a registration item (Regulation on the Registration of Market Entities, Article 8), and the company must show it has lawful use of the premises (SAMR Order No. 95, Article 18).1,2 That means a lease and the landlord’s evidence of title, for premises the registry will accept for the use you are registering. Addresses offered informally often cannot produce that paperwork, and the discovery usually comes after the name is approved.
2. The chops, and who holds them
A Chinese company acts through its chops rather than through signatures, and it will have several: the company chop, the legal representative’s chop, and finance and invoice chops. The engraver files each impression with the local public security authority within a day of carving it.3 The chops are usually in the quote. The custody arrangement never is, and it matters more: whoever holds the company chop can bind the company, as why a company chop outranks a signature explains.
3. The corporate bank account
The single most common omission, and usually the longest step. The bank account permit was abolished, in batches from 25 February 2019 and entirely by the end of that year,4 and account opening moved from approval to a filing.5 That removed a regulator’s licence, not the bank’s own review. Banks run their own checks on a new foreign-invested company, on their own timetable. The legal representative may open the account or authorise someone else (PBOC account measures, Article 26),6 but many banks want the legal representative’s identity verified by the bank itself, as registering without visiting sets out. A timeline that does not say whether the bank account is inside it is not a timeline.
4. Tax registration, and the taxpayer status that follows
The administrative half is nearly automatic: a company holding a unified-code business licence does not register again for tax.7 The consequential half is whether it is a general VAT taxpayer or a small-scale one, which governs how it invoices and what it can deduct.
- Below RMB 5 million of annual sales it is a choice. A business at or under the threshold is a small-scale taxpayer (VAT Law, Article 9), and one with sound accounts may register as a general taxpayer instead.8
- Above it, registration is compulsory, within the filing period of the month after the threshold is crossed, measured over any period of up to twelve months.9 Once a general taxpayer, a business cannot go back (Implementing Regulations, Article 36).10
- For an exporter it decides the refund. Goods exported by a small-scale taxpayer are exempt from VAT, not refunded (MOF and STA Announcement 2026 No. 11, Article 6),11 so a trading company that expects export refunds needs general-taxpayer status.
It is a structural decision that arrives disguised as a form.
5. Exporting in your own name
If the company is to export under its own name, the licence is roughly half the job. The remaining sequence changed between 2022 and 2026, and a great deal of English-language guidance still describes the old one.
| Step | What it is now |
|---|---|
| Foreign trade operator filing(对外贸易经营者备案登记) | Abolished on 30 December 2022. Under the Foreign Trade Law in force since 1 March 2026, any person or organisation that has completed market-entity registration is a foreign trade operator |
| Customs filing(报关单位备案) | A filing, granted within 3 working days, that does not expire. It can be ticked at company registration, with no separate application to customs |
| Electronic port enrolment | Made online. It no longer checks the customs filing or the foreign exchange directory, so the steps need not run in order |
| Foreign exchange directory registration | Made directly at a bank since 1 June 2024, not at a SAFE branch |
| Export refund filing | Made with the tax office when the company first claims a refund |
If a proposal lists the foreign trade operator filing as a step, that tells you when the proposal was written.19 If the customs box is not ticked at registration, the filing becomes a separate errand.15
6. The licensed bookkeeper, and the auditor
Three separate engagements, and none of them is the registration provider’s unless it holds the right approval. A company that does not keep its own books must use an approved bookkeeping agency (Accounting Law, Article 34),20 and an agency other than a CPA firm needs approval from the local finance authority (Bookkeeping Measures, Article 3).21 Tax agency is supervised by the tax authority, not the finance authority, and a provider must report its details to the tax authority before its first engagement (STA Order No. 58, Articles 10 and 12).22 An audit report on company accounts is issued through a CPA firm (CPA Law, Articles 14 and 16).23
The audit is not optional either. The Company Law requires the annual financial report to be audited by an accounting firm in accordance with law (Article 208),24 and for a foreign-invested company the bank enforces it: a profit remittance above US$50,000 is reviewed against audited financial statements (SAFE Huifa [2017] No. 3, item 7).25 Who else asks for the audit report is set out in what annual filings a Chinese company must make. A quote that appears to include bookkeeping or audit is worth a question about who holds the approval.
7. Registered capital is a five-year clock, not a badge
The subscribed capital of a limited liability company must be paid in within five years of establishment (Company Law, Article 47).24 A company registered on or before 30 June 2024 must, before 30 June 2027, bring any later payment date forward to 30 June 2032 or earlier (State Council Order No. 784, Article 2).26 Each shareholder’s subscribed and paid-in contributions are published by the company on the national publicity system (Company Law, Article 40).24 A large figure chosen to look substantial is therefore a public, dated commitment to transfer that money. The rule and the transition are set out in full in what registered capital is.
8. The annual report
Every company files an annual report for the previous year between 1 January and 30 June, and it is published (Interim Regulation on Enterprise Information Publicity, Article 8). A company that misses it is put on the abnormal operations list (Article 18),27 which anyone can see, including your banks, customers and partners. The whole filing calendar is in what annual filings a Chinese company must make.
Whose fee is whose?
| Item | Whose fee | Usually in a registration quote? |
|---|---|---|
| Name approval, documents, licence, chops | The provider’s | Yes |
| Registered address | Your landlord’s | No |
| Corporate bank account | The bank’s | No, and often not in the timeline either |
| Customs filing, electronic port, foreign exchange directory, export refund filing | Mostly official or at cost | No |
| Bookkeeping, tax filing, audit | An approved bookkeeping agency, a tax service provider and a CPA firm | No, unless the provider holds the approvals |
| Registered capital | Yours, within five years | Not a fee at all: a commitment |
What we are not claiming
We have not given you a number. Setup costs vary by city, vehicle, scope and bank, and a figure here would be repeated back as though it were a quotation. What we have given you is the list of things to make a provider address in writing, ours included. The question to put to any proposal is not “how much” but “which of these eight are inside your scope, and who does the rest?”
Nor is this a criticism of fixed-fee registration providers. Filing work is a real service and scoping it tightly is reasonable. The failure is asymmetric information, not dishonesty, and one written question fixes it. Whether a foreigner can own all of the company, and when a Chinese partner is needed, is answered in whether a foreigner can own 100% of a Chinese company.
The rules in this area move. Four of the steps above changed between 2022 and 2026. Any guidance you read on this subject, this page included, should carry the date it was last checked and a link to the rule it relies on.
Want a registration quote that leaves nothing out? Company Setup & Compliance Coordination We coordinate the registration from structure to bank account and tax registration, at a fixed fee that says in writing what it includes. From US$850, 4–8 weeks to a licensed company. See the service Sources
- Regulation on the Registration of Market Entities (State Council Order No. 746), in force 1 March 2022: Article 8, the address is a registration item (State Council Gazette, retrieved 21 September 2026)
- Measures for the Implementation of Company Registration Administration (SAMR Order No. 95), in force 10 February 2025: Article 18, proof of lawful use of the premises (State Council Gazette, retrieved 21 September 2026)
- Provisional Rules for the Administration of the Printing and Engraving Trade, Article 5(1), as revised by State Council Order No. 797, in force 20 January 2025: the engraver files the impression with the county-level public security authority within one day (Ministry of Justice administrative regulations database, retrieved 21 September 2026)
- People’s Bank of China Order [2019] No. 1, cancelling enterprise bank account licensing in batches from 25 February 2019 and entirely by the end of 2019 (State Council Gazette, retrieved 23 September 2026)
- People’s Bank of China, Yinfa [2019] No. 41: basic deposit accounts moved from approval to filing (gov.cn, retrieved 21 September 2026)
- People’s Bank of China Measures for the Administration of RMB Bank Settlement Accounts (Order [2003] No. 5): Article 26, the legal representative may open the account or authorise another person (State Council Gazette, retrieved 20 September 2026)
- State Taxation Administration, Shuizonghan [2015] No. 482: a company holding a unified-code business licence does not register again for tax and receives no tax registration certificate (Shanghai Tax Service, retrieved 21 September 2026)
- Value-Added Tax Law of the PRC, in force 1 January 2026: Article 9, the small-scale taxpayer threshold of RMB 5 million (State Taxation Administration policy library, retrieved 23 September 2026)
- STA Announcement 2026 No. 2 on general VAT taxpayer registration, in force 1 January 2026: items 3 and 5, annual sales over a period of up to 12 months, and registration within the filing period of the month after the threshold is crossed (Guangdong Provincial Tax Service copy, retrieved 23 September 2026)
- Implementing Regulations of the VAT Law (State Council Order No. 826), in force 1 January 2026: Article 36, general taxpayer registration, and no return to small-scale status (State Taxation Administration policy library, retrieved 23 September 2026)
- MOF and STA Announcement 2026 No. 11 on VAT and consumption tax policy for export business, in force 1 January 2026: Article 6, goods exported by a small-scale taxpayer are exempt, not refunded; Article 10, repealing 财税〔2012〕39号 (State Taxation Administration policy library, retrieved 23 September 2026)
- NPC Standing Committee Decision amending the Foreign Trade Law (Presidential Order No. 128), adopted and in force 30 December 2022: Article 9, the foreign trade operator filing, deleted (gov.cn, retrieved 23 September 2026)
- Foreign Trade Law of the PRC, revised 27 December 2025 (Presidential Order No. 67), in force 1 March 2026: Article 11, a foreign trade operator is a person or organisation that has completed market-entity registration (MOFCOM, retrieved 23 September 2026)
- GACC Provisions on the Filing of Customs Declaration Entities (GACC Decree No. 253), in force 1 January 2022: Article 7 (filing within 3 working days) and Article 8 (the filing does not expire) (State Council Gazette, retrieved 23 September 2026)
- GACC and SAMR Announcement 2021 No. 113, in force 1 January 2022: the customs declaration entity filing ticked at market-entity registration, with no separate application to customs (MOFCOM law database, retrieved 23 September 2026)
- GACC, MOFCOM, STA, SAMR and SAFE Announcement 2023 No. 164 on electronic port enrolment, 17 October 2023: item 3, enrolment no longer checks the customs filing or the foreign exchange directory (gov.cn, retrieved 23 September 2026)
- SAFE, Huifa [2024] No. 11 on further optimising trade foreign exchange administration, in force 1 June 2024: item 1, the trade foreign exchange directory registration made directly at a bank (gov.cn, retrieved 23 September 2026)
- STA Announcement 2026 No. 5, Measures for the Administration of Export VAT and Consumption Tax Refunds and Exemptions, in force 1 January 2026: Article 4 (the filing made at the first refund claim) and Article 7 (changes within 30 days) (State Taxation Administration policy library, retrieved 23 September 2026)
- MOFCOM Department of Foreign Trade: briefing on the abolition of the foreign trade operator filing, commerce departments stopping the filing from 30 December 2022, 3 January 2023 (gov.cn, retrieved 23 September 2026)
- Accounting Law of the PRC, as amended 28 June 2024, in force 1 July 2024: Article 34, the four ways of organising the accounting work, including outsourcing to an approved bookkeeping agency (State Taxation Administration policy library, retrieved 23 September 2026)
- Administrative Measures for Bookkeeping Agencies (MOF Order No. 80, as amended by MOF Order No. 98, 2019): Article 3, approval by a county-level or higher finance department (Beijing Municipal Government copy, retrieved 23 September 2026)
- Measures for Tax-Related Professional Services (Trial) (STA Order No. 58), in force 1 May 2025: Articles 10 and 12, tax agent firms registered with the tax authority, and service providers reporting their details before their first engagement (State Taxation Administration policy library, retrieved 23 September 2026)
- Law of the PRC on Certified Public Accountants, as amended 31 August 2014: Articles 14 and 16, audit reports on company accounts issued through a CPA firm; an amendment takes effect on 1 January 2027 (MOF, retrieved 23 September 2026)
- Company Law of the PRC, revised 29 December 2023, in force 1 July 2024: Article 40 (what the company publishes), Article 47 (five years to pay in a limited liability company’s subscribed capital) and Article 208 (financial reports audited where the law requires) (gov.cn, retrieved 22 and 23 September 2026)
- SAFE, Huifa [2017] No. 3: item 7, a profit remittance above USD 50,000 reviewed against the profit distribution resolution, the tax filing form and audited financial statements; current on SAFE’s list at 31 December 2025 (safe.gov.cn, retrieved 23 September 2026)
- State Council Regulation on the registered capital registration system under the Company Law (国务院令第784号), in force 1 July 2024: Article 2, the transition for companies registered on or before 30 June 2024 (gov.cn, retrieved 22 September 2026)
- Interim Regulation on Enterprise Information Publicity, as revised 10 March 2024: Article 8 (the annual report, 1 January to 30 June) and Article 18 (the abnormal operations list) (SAMR, retrieved 23 September 2026)
All sources checked 23 September 2026. This page is general information, not legal, tax or customs advice. Requirements vary by product, market and circumstance. Confirm your own position before acting.
