What does a Chinese company’s annual report tell you?
What is filed by 30 June, what the national register shows and what it may keep back, spot checks, the abnormal operations list, the serious violation list — and how to read them in a KYC file
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China abolished the annual inspection of companies in 2014 and replaced it with a duty to report and to publish. Every year, between 1 January and 30 June, each company registered in mainland China files an annual report (年度报告) on the preceding year through the National Enterprise Credit Information Publicity System (GSXT), and most of it becomes public at once. Nobody approves it in advance: the authorities check a sample afterwards, and a company that does not file, or cannot be found, is placed on the list of enterprises with abnormal operations. This note sets out what is filed and on which year, what is published and what the company may keep back, how the spot checks work, how a company enters and leaves the abnormal operations list, what replaced the old three-year rule — and how to read all of it in a KYC file.
What is filed, by when, and on which year?
The Interim Regulations on Enterprise Information Publicity (企业信息公示暂行条例), as revised by State Council Decree No. 777 with effect from 1 May 2024, require every company to submit its annual report on the preceding year to the market regulation authority between 1 January and 30 June, through the GSXT, and to publish it there. A company incorporated during a year files for the first time the following year (art. 8). The report filed in 2026 thus covers 2025. Mistakes may be corrected, but corrections to the annual report must be made by 30 June, and the old and new versions are then shown side by side (art. 12).
A foreign-invested enterprise files the same report, by the same date and through the same system; it also serves as its annual foreign investment information report to the Ministry of Commerce (Foreign Investment Information Reporting Measures, MOFCOM–SAMR Order [2019] No. 2, arts. 14 and 18).
| Term | What it means in practice |
|---|---|
| Annual report 年度报告 | The company’s own declaration on the preceding year, filed online between 1 January and 30 June. It is not approved beforehand and not audited by the registry. |
| National register (GSXT) 国家企业信用信息公示系统 | The national public platform run by SAMR (gsxt.gov.cn), where registration data, annual reports, penalties and list entries are published. |
| Instant information 即时信息 | Information the company must publish within 20 working days of any change during the year: capital contributions, share transfers, licences, penalties (Regulations, art. 10). |
| Abnormal operations list 经营异常名录 | The list of enterprises with abnormal operations, on which the registration authority places a company that has failed to file, to publish or to be reachable. |
| Serious violation list 严重违法失信名单 | The list of seriously illegal and dishonest enterprises: a sanction for serious offences, kept by the market regulators. |
| Credit repair 信用修复 | The procedure by which a company that has put matters right is taken off a list (Regulations, art. 20). |
What is made public, and what may the company keep back?
Article 9 of the Regulations lists seven headings. The first six must be published. The seventh — the figures — is published only if the company chooses to publish it.
| Heading of the annual report | On the GSXT |
|---|---|
| 1 · Contact details: postal address, postcode, telephone, e-mail | Published |
| 2 · Status: in business, suspended or in liquidation | Published |
| 3 · Investments: companies set up by the company, equity it has bought | Published |
| 4 · Capital: each shareholder’s subscribed and paid-in contributions, with their dates and form | Published |
| 5 · Share transfers and other changes in the shareholding of a limited liability company | Published |
| 6 · Websites and online shops: names and addresses | Published |
| 7 · Figures: number of employees, total assets, total liabilities, guarantees given to third parties, owners’ equity, total revenue, revenue from the main business, total profit, net profit, total tax paid | Company’s choice |
With the company’s consent, anyone may consult the information it has chosen not to publish (art. 9). In practice the online form adds a social insurance section, fed by the tax and social security authorities: the number of insured employees, scheme by scheme, is usually shown, while the contribution base, the amounts paid and any arrears are often marked “not published” at the company’s choice. The Company Law makes the publication of the capital, the share changes and the licences a duty of the company itself, which must ensure that what it publishes is true, accurate and complete (Company Law, art. 40).
Concealing or falsifying published information is punished by an order to correct and a fine of RMB 10,000 to 50,000 (about USD 1,500 to 7,400); in serious cases, RMB 50,000 to 200,000 (about USD 7,400 to 29,800), entry on the serious violation list and possible revocation of the business licence (Regulations, art. 18; for the capital and share information, Company Law, art. 251, which adds fines of RMB 10,000 to 100,000, about USD 1,500 to 14,900, for the individuals responsible).
Who checks what the company declares?
No one checks the report before it is published. The control comes afterwards, by sampling. Under the Measures for Spot Checks of Information Published by Enterprises (企业公示信息抽查办法, SAIC Order No. 67 of 2014, revised by SAMR Order No. 101 of 18 March 2025), SAMR and the provincial authorities draw companies at random from their unified social credit codes, weighted by credit-risk classification; each list covers at least 3% of the companies in the jurisdiction (art. 4). One general check is run every year, after the 30 June window has closed (art. 7); targeted checks may be drawn by type, size, industry or region (art. 5), and any company may be inspected on a complaint or a tip-off that its information is false (art. 6).
The inspectors review documents, visit the premises and monitor the company online; they may ask for the accounts and other records, and may call on outside accountants or lawyers (arts. 8–10). Since 1 May 2024 they may also, with the approval of the head of the authority, query the bank accounts of a company suspected of a violation (Regulations, art. 16). The result is entered on the company’s public record within 20 working days of the end of the check (Spot-Check Measures, art. 12); a serious refusal to cooperate is itself published (art. 10).
When is a company placed on the abnormal operations list?
The Measures for the Administration of the Abnormal Operations List (企业经营异常名录管理办法, SAIC Order No. 68 of 2014, revised and renamed by SAMR Order No. 101, in force since 1 May 2025) give four grounds. The county or city registration authority must list the company, and the entry is published on the GSXT with its date, ground and authority (arts. 4 and 5).
| Ground | When the entry is made | How the company leaves the list |
|---|---|---|
| Annual report not published by 30 June | Within 10 working days after 30 June (art. 6) | File and publish the missing reports, then apply; decision within 5 working days (art. 11) |
| Instant information not published within the period ordered by the authority (at least 10 days) | Within 10 working days after the period expires (art. 7) | Publish the information, then apply; decision within 5 working days (art. 12) |
| Change of name not registered as required by the name registration rules | Within 10 working days after the deadline (art. 8) | Register the change; decision within 5 working days of verification (art. 13) |
| Unreachable at the registered domicile or place of business | Within 10 working days of verification — for instance, two registered letters 15 to 30 days apart left unsigned (art. 9) | Register a new address, or show that it can be reached there; decision within 5 working days of verification (art. 14) |
The entry has consequences beyond the record. The company may be fined up to RMB 10,000 (about USD 1,500) for a late report (SAMR Order No. 52, art. 70). Governments must take the record into account in public procurement, tenders, grants of state land and honours, and may restrict or exclude listed companies (Regulations, art. 19); local rules add closer inspection and restrictions on subsidies and preferential policies. A company may object within 30 days of publication; the authority must verify within 20 working days and correct any error (Measures, art. 15).
Does a company still move to the serious violation list after three years?
No longer automatically. Under the 2014 version of the Regulations, a company still on the abnormal operations list after three years was transferred to the list of seriously illegal enterprises, its legal representative was barred for three years, and it came off only after five years without further breach (former art. 17). State Council Decree No. 777 replaced that rule with effect from 1 May 2024: a company that has been listed for failing to file its annual report for two consecutive years, has not put matters right, and cannot be reached at its registered domicile or place of business, now has its business licence revoked — and must then deregister (Regulations, art. 18).
The serious violation list remains, but as a sanction for serious offences: a company that has published false information in a serious case (Regulations, art. 18), or that has received a heavier administrative penalty from the market regulators for a serious breach (SAMR Order No. 44 of 30 July 2021, Measures for the Administration of the Serious Violation and Dishonesty List, art. 2). The decision to list is taken together with the penalty decision (art. 13).
| Serious violation list | What it entails |
|---|---|
| Measures 管理措施 | An important factor in licences, qualifications, public procurement and tenders; priority supervision with more frequent inspections; no approval on simple commitment; no honours from the market regulators (art. 15). |
| Legal representative 法定代表人 | The legal representative or person in charge may not hold that position in any other company for 3 years (Regulations, art. 18). |
| Removal 移出 | After 3 years from listing (art. 21), or on application after at least 1 year, once the penalty is paid, the harm remedied and no further heavy penalty imposed (art. 16). Publication stops within 3 working days of removal (art. 18). |
What disappears from the record?
Since 1 May 2025, when a company is taken off the abnormal operations list, the GSXT stops publishing the entry (Measures, art. 10). Before, the page kept the entry with its date of listing and its date of removal. SAMR applied the change to past records as well: by May 2025, 48.4 million entries concerning 25.5 million businesses — 5.0 million of them companies — were no longer shown. The serious violation list works the same way: once a company is removed, the entry disappears from the public record.
For a reader, this means that a clean GSXT page today shows the present position, not the history. A company that went through two years of missing reports and an unreachable address, then filed and moved, may look exactly like one that never missed a deadline. Commercial databases that captured the record earlier may still show the old entries.
How should you read all this in a KYC file?
| Sign | Why it matters |
|---|---|
| No annual report for the last year, after 30 June. | The company is, or will be, on the abnormal operations list. |
| Listed because it cannot be reached at its registered address. | Perhaps no real premises; two years of this, with reports missing, lead to revocation. |
| Paid-in capital nil, or no insured employees, for a company presented as active. | The declared resources do not match the story. |
| A correction of the annual report, or a spot-check finding. | Something declared was wrong; read the old and new versions. |
| An entry on the serious violation list. | A serious offence; its legal representative is barred for three years. |
Everything in the annual report is written by the company. The registry publishes it, samples a small share of it and sanctions what it finds — but it vouches for none of it. Read the report as the company’s own statement: check that it exists, that it is complete and that it agrees with the other records, and treat a page without entries as today’s picture, not as a clean history.
How can CCSS help?
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www.china-company-search.com — Report Types › KYC Corporate Report — Advanced