In January 2018, the China Banking Regulatory Commission (CBRC) issued Interim Measures for the Equity Management of Commercial Banks which require that any investor (together with its persons acting in concert) holding 1% or more of equity interests of a PRC commercial bank is subject to a post-notification requirement due within 10 working days.

This post-notification requirement applies to both investors holding equity and listed shares (including A shares and H shares). Consequently, it applies to all QFIIs, RQFIIs, investors investing in A shares through the Stock Connect regime, and investors investing simply in H shares issued by PRC commercial banks.

Under the prevailing PRC and HK disclosure of interest rules, investors are generally only required to monitor shareholding once a 5% threshold has been reached. Investors should examine their positions to check if their holdings (together with the holdings of their persons acting in concert) in a PRC commercial bank have reached 1%, and determine if a notification to the CBRC (now the China Banking and Insurance Regulatory Commission) should be made. Deacons can draft and assist with notification reports.