There are onlyTwo weeksThe

This is no longer a topic you can put off until later. After July 1, the rules will change completely, and how much preparation you do before then will determine whether you make a smooth transition or are forced to react.

This is not an exaggeration. Each of the following five steps corresponds to a key compliance milestone.If you’ve done 4 or more of these—you’re basically safe. If you haven’t done any—the window of opportunity is closing.

It takes about 5 minutes to read this article. But what you might save is a fine of hundreds of thousands and the fate of a company.

Step 1: Check whether your Hong Kong company has an ODI filing

Done: Verify that your ODI certificate is valid and that its filing scope covers your business operations. If there are any changes (such as to shareholders, business scope, or investment amount), you must file an amendment.

Not done:

• ⚠️ You can still apply for a replacement under the current standards before July 1.
• ⚠️ After July 1, approval standards will be raised, documentation requirements will become stricter, and the approval rate will decrease.
• ⚠️ Failure to complete the renewal → Compliance risks for the Hong Kong company structure → The bank may freeze the account

Take Action Now: Log in to the Ministry of Commerce’s “Overseas Investment Management System” to check the status of your ODI filing. Alternatively, contact your agent directly to verify the status.

📌 Not sure how to check, found nothing after checking, or still don't know what's missing after checking?
Scroll to the bottom of the article, where we offerFree Emergency Compliance Assessment—It tells you exactly where you're falling short, what you can improve, and how to do it.Cell phone: 18676749275 ｜ WeChat: qcygscszk

Step 2: Organize the Hong Kong company’s business records

The core requirement of Order No. 837 is “substantive business operations.” How will you prove that your Hong Kong company is engaged in substantive business operations?

Minimum System Requirements:

In a nutshell: If a bank or the tax office asks you for documents after July 1, your response should be, “Hold on, I’ll send them to you right away,” rather than, “I’ll go home and get them together.”

Step 3: Review the Fund Reflow Path

How does your Hong Kong company repatriate its profits to the mainland? Is the capital repatriation process compliant?

Three common paths; check them one by one:

Each route comes with a corresponding set of compliance documentation. If your current method of repatriating funds would not stand up to scrutiny,It's not too late to change course now.

Step 4: Confirm Your Personal Registration Under Document No. 37

If your Hong Kong company is registered asIn an individual's nameIf the company is registered (rather than in the name of a domestic enterprise), the compliance requirement you face is not ODI filing, but ratherForeign Exchange Registration under Document No. 37.

Quick Assessment:

• The shareholder of a Hong Kong company is registered under your personal name → Document No. 37 is required
• The shareholder of the Hong Kong company is a mainland company registered in your name → ODI filing is required
• Neither situation has been filed → Evaluate a plan of action by July 1

If an individual holds shares but has not registered in accordance with Document No. 37, and the investment involves a “round-trip” structure (where a Hong Kong company holds a controlling stake in a mainland company), your compliance gap is twofold.

Step 5: Schedule a compliance review of your accounts

This is probably the most important—and most easily overlooked—of the five movements.

What to Review:

• How much has your Hong Kong company actually earned? (Not an estimate—it’s a precise calculation based on bank statements and platform data.)
• Is the cost structure clear? Is there documentation for each expense?
• If there are sister companies or affiliated companies, are there records and agreements regarding related-party transactions?
• Have there been instances of “blurring the line between public and private use” in the past? Can this still be remedied?

Only after you've sorted it all out will you realize: How far we still fall short of the requirements of Order No. 837, what can be done immediately, and what requires the involvement of professional organizations.

At this point, you might realize that there are some things you just can’t handle on your own. That’s okay—it’s not your area of expertise. You'll find our team's contact information at the end of this article. The consultants at Qicaiying are here to help you handle all of these matters.

5 Actions, Each With Its Own Consequences

Qicaiying: 5 Steps to Take Before July 1

Qicaiying Group has specialized in cross-border financial and tax compliance for over 10 years, offering:

• ✅ Full-Service ODI Filing Assistance + Reapplication Evaluation: If you can make up for it, do so; if not, plan an alternative solution.
• ✅ Compilation of Hong Kong Company Operational Data + Establishment of Compliant Accounting Records: Helps you turn scattered transaction records into a complete, compliant file
• ✅ Planning the Path for Capital Repatriation: Dividends, trade in services, or repatriation of procurement—which route works for you? Let me help you design a plan.
• ✅ Document No. 37 Registration Agency Services: One-Stop Service for Foreign Exchange Registration of Individual Overseas SPVs

With only two weeks left in the window, now is the best time to get started.

🔍 Urgent Compliance Assessment Before July 1

I'm not sure how many of these 5 exercises you've done—and how many you still have left to do?
Not sure whether to follow ODI or Document No. 37?
Are you worried that the path of capital repatriation doesn't hold up?

Stop guessing. Let us help you conduct a professional compliance assessment.

This assessment includes the following:

• ✅ Assessment of Your Completion of the 5 Tasks (Scored Item by Item)
• ✅ Where are the gaps, and how high are the risks?
• ✅ What other exercises can I do within the next two weeks, and how should I schedule them?
• ✅ For areas requiring professional involvement, we’ll provide you with a clear timeline and budget range

Cell phone: 18676749275 ｜ WeChat: qcygscszk

⚠️ Only two weeks left until July 1

About Enterprise Caiying Group

Established in 2015 and headquartered in Shenzhen, Qicaiying Group specializes in providing one-stop financial, tax, and corporate compliance services to cross-border e-commerce companies and businesses expanding overseas. Its services include Hong Kong/ overseas company registration, bank account opening, cross-border financial and tax compliance, ODI filing, Circular No. 37 registration, Hong Kong compliance accounting, auditing, and tax filing, structural planning, VAT/EPR registration, bookkeeping services, and corporate identity planning. The group has served over 500,000 enterprises to date.