In order to accelerate the business registration reform and simplify the current registration procedures in China, the State Council issued the Opinions of the General Office of the State Council on Accelerating the Registration Reform of Consolidating Three Certificates into One Certificate [Guo Ban Fa [2015] No. 50] on June 23, 2015. This announcement related to the implementation of the "Three-in-One Registration Reform", under which the current version of business license, organization code certificate and tax registration certificate will be combined into one integrated business license. This has now been implemented and will come into effect on October 1, 2015.

Following the issuance of the above Opinions, the State Administration of Industry and Commerce ("AIC"), the State Administration of Taxation and other relevant government authorities jointly issued the detailed implementation rules for the Three-in-One Registration Reform. The implementation rules clarified certain matters relating to the simplified registration procedures (i.e. combining the current AIC registration, organization code registration and tax registration into one registration) and the new documentation requirements for enterprises to carry out registrations under the new procedures.

The relevant government authorities at provincial and municipal levels have published the new version of filing forms to be adopted starting from October 1 for their respective jurisdictions. However, since the registration is newly announced, quite a number of working level officers are not clear about the details of some local documentation requirements. It is expected that some local governments will issue further detailed guidance (such as Q&A guidance) to the public after several weeks of implementation under the new system.

In most cities, there will be a transitional period (from one to several weeks depending on local practices), during which the old registration forms and filing documents are still acceptable such that those enterprises which are in the middle of any corporate changes do not have to re-execute the new version of registration forms.

For enterprises that have recently applied for change of registration particulars and new setups, it is advised to make inquiries with the local authorities to ascertain the new filing requirements and procedures to avoid unnecessary delays to the registration process and business operations.