In 2026, the trend of Chinese companies expanding into Singapore continued to gain momentum, but the thresholds and regulatory scrutiny for ODI (Outbound Direct Investment) filings have also been tightened. The latest policy stipulates that, starting in 2026, ODI filing will follow the principle of ”no monetary threshold and penetrative supervision”—regardless of the investment amount, even as little as $10,000, any domestic enterprise that establishes a new company, acquires an existing one, or takes an equity stake in a Singaporean company—provided that its shareholding reaches 10% or it exercises actual control—must file a report. At the same time, regulators will look through multi-layered offshore structures to trace investments back to the actual domestic controllers, strictly prohibiting the use of special-purpose vehicles (SPVs) for indirect investment to circumvent filing requirements. This means that, in the past,

In 2026, China’s outbound direct investment (ODI) filing system underwent a major transformation—the regulatory approach shifted from ”threshold-based approval” to ”threshold-free, penetrative supervision.” The new regulations stipulate that there will no longer be a monetary threshold for corporate overseas investment; any overseas investment involving a shareholding ratio of 10% or more, or where the enterprise exercises actual control, must undergo ODI filing. This means that whether it is a greenfield manufacturing project involving hundreds of millions of U.S. dollars or the establishment of an overseas sales company with a registered capital of tens of thousands of U.S. dollars, as long as the equity stake or control meets the threshold, the filing process must be completed. An even more profound change is ”penetrative supervision”—multi-layered offshore structures

On July 1, 2026, State Council Order No. 837 officially took effect, marking the entry of China’s outbound investment regulation into a new phase of ”full-process supervision.” The core change in this regulation is that ODI (Outward Direct Investment) filing has shifted from ”post-facto reporting” to a ”pre-approval procedure”—enterprises must complete the filing before funds leave the country; otherwise, banks will not process foreign exchange purchases or remittances. More strictly, violations will be subject to fines ranging from 1‰ to 10‰ of the investment amount, completely closing off the gray-area practice of ”implementing the project first and filing for record-filing later.” For enterprises planning to build factories overseas, establish overseas companies, or set up red-chip structures, Decree No. 837

In 2026, an increasing number of Chinese companies began to reexamine a key question: Have the overseas entities they established through various channels back then truly completed their ODI filing?

December 31, 2026—This is the final deadline for all entities that established overseas enterprises without first obtaining ODI filing to submit their retroactive filings. Entities that fail to file by this deadline will be placed on the foreign exchange watch list and prohibited from conducting any foreign exchange transactions related to overseas investment.