CHINA Law and Practice Contributed by: Zhen Chen, Candy Tang, Flora Qian and Yan Zhao, Fangda Partners
Fangda Partners 24/F HKRI Centre Two HKRI Taikoo Hui 288 Shi Men Yi Road Shanghai 200041 China Tel: (8621) 2208 1166 Fax: (8621) 5298 5599 Email: email@fangdalaw.com Web: www.fangdalaw.com
1. General 1.1 General Overview of Jurisdiction
the fund management businesses contemplated in the relevant local regulations. Local financial services offices or similar authorities (FSOs) typically lead a local joint committee to carry out the approval func - tions. According to AMAC’s statistics, as of June 2025, there are 19,756 private fund managers with a total of 140,558 private fund products and an aggregate asset size of RMB20.26 trillion. From a regional perspec - tive, the cities and/or provinces with more than 1,000 private fund managers and trillion-level AUMs include Shanghai, Beijing, Shenzhen, Guangdong Province (excluding Shenzhen), and Jiangsu Province. Such geographical distribution also largely corresponds to the favourable locations that global sponsors would typically consider and tend to choose for the estab - lishment of their private fund managers and funds in China. In terms of fund manager registration and deregis - tration, AMAC has adopted a regulatory attitude of “strict entry, lenient exit” over 2024 and the first half of 2025, further tightening control over the entry of new managers and streamlining the overall sector. The average number of new fund manager registra - tions per month has been kept at around 13 (with new private equity fund managers typically outnumbering those in the securities fund category). Meanwhile, the average number of deregistered fund managers per month has reached approximately 114. In terms of fund numbers, early-established funds have started to enter their liquidation cycles, with many completing
China’s regulatory framework for private funds has gradually matured and become more sophisticated over the past decade. A comprehensive regulatory system has been established, comprising the China Securities Regulatory Commission (CSRC) and the Asset Management Association of China (AMAC) at its core and other applicable authorities, mainly including the National Financial Regulatory Admin - istration (NFRA, formerly known as the China Bank - ing and Insurance Regulatory Commission (CBIRC), as the primary regulator for insurance investors), the State Administration of Foreign Exchange (SAFE, as the regulator for cross-border capital remittance), and local counterparts of the Administration for Mar - ket Regulation (AMR, as the regulators for enterprise registration). In general, China maintains a registration/filing system for all private funds. A private fund manager has to complete a registration process with AMAC before it can conduct any fundraising activities, and a filing has to be made for any private fund promptly after it has been closed. In addition, certain local pilot programmes such as the Qualified Foreign Limited Partner (QFLP), the Qualified Domestic Limited Partner (QDLP) and/or the Qualified Domestic Investment Enterprise (QDIE) also involve an approval procedure at the local government level. Once “approved”, a fund manager can then carry out
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