On July 1, 2026, the Provisions of the State Council on Outbound Investment (the "Provisions"), promulgated by State Council Decree No. 837, came into force. One of their most closely watched features is the express inclusion, at the level of an administrative regulation, of "resident individuals in China" within the definition of "Investors". The change follows years of growth in cross-border asset allocation by individuals and families in the Chinese mainland. Portfolios that once centered on equities listed in the Hong Kong Special Administrative Region ("Hong Kong SAR") or the United States, and on funds and insurance policies established or issued outside the Chinese mainland, now often extend to real estate outside the Chinese mainland, family trusts and other structures. Regulatory data infrastructure has also matured. Financial-account information exchanged under the Common Reporting Standard (CRS), bank know-your-customer (KYC) records, foreign-exchange receipts and payments, individual income tax filings, entry and exit records, and anti-money-laundering monitoring may, subject to applicable law and implementation arrangements, make cross-border fund flows, accounts and asset structures easier to identify and assess.

Since 2026, China has witnessed significant developments in the regulatory framework governing outbound investment by individuals. For Chinese high-net-worth individuals ("HNWIs"), cross-border investment has entered a new era in which tax compliance has become an integral component of wealth planning and global asset allocation. Several recent developments illustrate this trend. First, at the legislative level, the Regulations of the State Council on Outbound Investment (《国务院关于对外投资的规定》, State Council Order No. 837) came into effect on 1 July 2026. As China's first administrative regulation specifically governing outbound investment, the Regulations expressly include PRC individual residents within the regulatory framework, marking the first time that outbound investment activities conducted by individuals have been systematically incorporated into a unified national regulatory regime.

On March 19, 2025, the General Affairs Department of the National Medical Products Administration ("NMPA") issued the Implementation Measures for Regulatory Data Protection (Trial, Draft for Comments) (the "Draft for Comments") and the Working Procedures for Regulatory Data Protection (Draft for Comments) to further advance the implementation of the Regulatory Data Protection system (the "RDP System")(For an analysis of these two documents, please refer to our previously published article: A New Perspective on Innovative Drug Transactions: Analysis of the New Draft of the Regulatory Data Protection System (Bilingual)).