Companies with approval from Shanghai SAFE are required to annually re-register their equity plans with Shanghai SAFE. Shanghai SAFE began accepting annual re-registration applications on October 8th.

Companies should aim to complete their annual re-registrations for 2014 before December 31, 2013, because, in the absence of an approved re-registration, companies likely will not be able to send funds into or out of their SAFE-approved bank accounts on or after January 1, 2014.

While Beijing SAFE does not require an annual re-registration, companies are required to file amendment applications to obtain approval for any changes since the initial application (or the last amendment application). Changes to the employee list provided with the SAFE application trigger the need for an amendment application.

Thus, at least on an annual basis, companies should file an amendment application to update the employee list and make any other amendments to the approval, as necessary (e.g., establishment/acquistion of new subsidiaries, broker change, etc.).

Other SAFE offices may also require companies to annually re-register their plans or update their registrations.

Finally, if companies offer an ESPP or other awards which require an outward remittance of funds, it will likely be necessary to obtain a new outbound quota for 2014.