Any companies incorporated in China (including both domestic companies and foreign-invested companies, regardless of whether they are existing or newly established companies) have recently become required by the Chinese government to undertake certain company information disclosure obligations through an “Enterprise Credit and Information Disclosure System” newly launched by the company registration authorities in China. This new system aims to improve and replace the company annual inspection system that has been used in mainland China for many years. We recommend that the China affiliates of multinational companies become familiar with the Disclosure System to comply with the disclosure obligations.

The State Council promulgated The Provisional Rules on Enterprise Information Disclosure (the “Disclosure Rules”) on August 7, 2014. The rules take effect on October 1, 2014. In general, the key goals of the Disclosure Rules are to establish a nationwide disclosure system to allow the public to access the creditworthiness of any company registered in mainland China, and to provide more open and transparent information regarding corporate entities.