On 17 January 2017 China’s State Council published a Circular on Several Measures for the Active Use of Foreign Investment and Expanding Opening (“Circular”, Guo Fa [2017] No. 5, dated 12 January 2017). This Circular contains 20 measures for boosting foreign investment in China. As one of these 20 measures the State Council has once again unequivocally confirmed that unless national laws and/or the State Council’s administrative regulations provide for otherwise, no special minimum registered capital for foreign-invested companies is required and foreign-invested companies and domestic companies shall be treated equally in this regard. The following table is a non-exhaustive summary of China’s direct statutory requirements for minimum registered capital that we until now have identified in the national laws and the State Council’s administrative regulations. However, since the statutory requirements for foreign-invested enterprises regarding the ratio between the total investment amount and the registered capital still apply and financing by foreign loans may not exceed the gap between the total investment amount and the registered capital, the foreign investors should equip their foreign-invested enterprises with adequate registered capital in order to avoid potential liquidity problems.

Sector Minimum Registered Capital
Accounting firm with limited liability RMB 300,000
Auction enterprise RMB 1 Million
Bank card clearing institution RMB 1 Billion
Certification institution RMB 3 Million
Commercial bank RMB 50 Million – 1 Billion (depending on the specific business scope; RMB 1 Billion for foreign-invested banks)
Credit investigation institution engaged in individual credit investigation RMB 50 Million
Cultural heritage store RMB 2 Million
Direct selling company RMB 80 Million
Express delivery services RMB 500,000 – RMB 2 Million (depending on the specific business scope)
Fertilizer business operation company RMB 10 Million – 30 Million
Financial asset management company RMB 10 Billion
Foreign-invested telecommunications enterprise RMB 1 Million – 1 Billion (depending on the specific business scope)
Foreign labour service cooperation enterprise RMB 6 Million
Funds management company for managing publicly raised fund RMB 100 Million
Futures company RMB 30 Million
Insurance company RMB 200 Million
Labour dispatch company RMB 2 Million
Publishing house RMB 300,000
Real estate development company RMB 1 Million
Scrap car recycling enterprise RMB 500,000
Securities and futures investment consultancy RMB 1 Million
Securities company RMB 50 Million – 500 Million (depending on the specific business scope)
Security and guarding services RMB 1 Million – 10 Million (depending on the specific business scope)
Travel agency RMB 300,000