Entity Setup

China Registered Capital Requirements: Subscribed vs Paid-In System Explained

📅 January 20, 2026 ⏱️ 9 min read

Registered capital is one of the most misunderstood aspects of setting up a company in China. Since the 2014 reform that shifted China from a paid-in to a subscribed capital system, the rules have fundamentally changed. This guide explains how registered capital works, how to determine the right amount, and the capital injection process.

What Is Registered Capital?

Registered capital (注册资本) is the total capital that shareholders commit to contribute to the company. It represents the company's financial foundation and the shareholders' liability limit. In China, the registered capital is recorded on the Business License and is publicly visible on the National Enterprise Credit Information Publicity System.

Subscribed vs Paid-In Capital System

Old System (Before 2014): Paid-In Capital

Under the old system, companies had to deposit the full registered capital before registration. A capital verification report (验资报告) from a CPA firm was mandatory. This created significant cash flow pressure for startups.

Current System (After 2014): Subscribed Capital

The 2014 Company Law reform introduced the subscribed capital system:

  • Shareholders declare the total registered capital and a contribution deadline (up to 30 years, or longer in some cases)
  • No upfront deposit is required
  • No capital verification report is needed for registration
  • Capital can be injected gradually over the contribution period
  • The registered capital appears on the Business License
2024 Company Law Update: The revised Company Law (effective July 1, 2024) requires that subscribed capital be fully paid within 5 years of establishment for new companies (transitional rules apply to existing companies). This significantly shortens the previously flexible contribution period.

How to Determine the Right Registered Capital

Factors to Consider

  • Operational needs: Capital should cover at least 6-12 months of operating expenses (rent, salaries, taxes, supplies).
  • Industry requirements: Certain industries (banking, insurance, construction, freight forwarding) have statutory minimum capital requirements.
  • Credibility: A higher registered capital enhances credibility with banks, suppliers, and customers. Many Chinese companies check registered capital as a trust signal.
  • Government bidding: Government procurement projects often have minimum registered capital thresholds.
  • Visa applications: Some cities require a minimum capital (e.g., RMB 100K-500K) to sponsor foreign employee work permits.

Recommended Capital by Industry

IndustryRecommended Capital (RMB)Reasoning
Consulting/Advisory100,000 - 500,000Low fixed costs, minimal equipment
Technology/R&D500,000 - 2,000,000Salaries, equipment, potential HNTE application
Trading/Import-Export500,000 - 1,000,000Inventory, customs bonding, credit lines
E-commerce500,000 - 1,000,000Platform deposits, inventory, logistics
Manufacturing (small)1,000,000 - 3,000,000Equipment, facility, raw materials
Manufacturing (large)3,000,000 - 10,000,000+Scale-dependent, environmental assessment
Food & Beverage500,000 - 2,000,000License requirements, equipment, deposits
Education/Training1,000,000 - 3,000,000Regulatory minimums vary by city

Capital Injection Process

Step 1: Open Foreign Exchange Capital Account

After WFOE registration, open a Foreign Exchange Capital Account (外汇资本金账户) at a Chinese bank authorized to handle foreign exchange. You will need:

  • Business License
  • Foreign Direct Investment (FDI) registration with SAFE/bank
  • Articles of Association showing capital amount
  • Shareholder details and identification

Step 2: Remit Capital from Abroad

The foreign shareholder remits the capital in foreign currency (USD, EUR, HKD, etc.) to the Foreign Exchange Capital Account. The remittance must include a clear payment purpose such as "Capital contribution to [Company Name]."

Step 3: Foreign Exchange Settlement

Upon receiving the foreign currency, the bank converts it to RMB at the prevailing exchange rate. The RMB funds are deposited in the company's RMB Capital Account (资本金账户). This conversion is subject to SAFE's foreign exchange registration.

Step 4: Capital Verification (Optional but Recommended)

While not legally required, obtaining a capital verification report (验资报告) from a CPA firm is recommended for:

  • Bank loan applications
  • Government bidding requirements
  • Future capital increases or corporate restructuring
  • Visa applications for foreign employees

Step 5: Transfer to Operating Account

Once the capital is verified and settled, transfer the RMB funds from the Capital Account to the RMB Basic Account (基本户) for daily operational use. The bank will monitor usage to ensure funds are used for legitimate business purposes.

Capital Usage Rules

Registered capital can be used for legitimate business expenses:

  • ✅ Office rent and utilities
  • ✅ Employee salaries and social insurance
  • ✅ Equipment and inventory purchases
  • ✅ Marketing and business development
  • ✅ Loan repayment (with bank approval)
  • ❌ Personal use by shareholders
  • ❌ Investment in restricted sectors without approval
  • ❌ Direct real estate speculation
Important: The bank will review payment instructions from the Capital Account. Large or unusual payments may require supporting documentation (invoices, contracts). This is known as "verification of authenticity" (真实性审核) under SAFE regulations.

Capital Increase

If you need to increase registered capital after establishment:

  1. Board/shareholder resolution approving the increase
  2. Amend the Articles of Association
  3. File amendment with AMR (3-10 business days)
  4. Update FDI registration with SAFE/bank
  5. Remit additional capital through the Foreign Exchange Capital Account
  6. Complete settlement and verification

The process typically takes 4-6 weeks.

Capital Reduction

Reducing registered capital is more complex than increasing it:

  1. Board/shareholder resolution
  2. Prepare debt clearance statement or debt guarantee arrangement
  3. Publish a public notice in a designated newspaper (45-day creditor objection period)
  4. File amendment with AMR after the 45-day period
  5. Update tax and SAFE registrations
  6. Repatriate excess capital through approved foreign exchange channels

The entire process takes 2-3 months.

Industry-Specific Minimum Capital Requirements

IndustryMinimum Capital (RMB)Regulatory Basis
Commercial banks1,000,000,000Commercial Banking Law
Insurance companies200,000,000Insurance Law
Securities firms50,000,000 - 500,000,000Securities Law
International freight forwarding500,000 (3M for sea)MOFCOM regulations
Construction (Grade 1)50,000,000+Ministry of Housing
Third-party payment100,000,000PBOC regulations
Healthcare/Medical institutionsVaries by provinceLocal health authority

Common Mistakes to Avoid

  • Setting capital too low: Capital of RMB 10,000 may look unserious to partners and banks. Even if legally allowed, set a practical amount.
  • Setting capital too high: Under the 2024 Company Law, you must pay the full amount within 5 years. Setting capital at RMB 50 million when you only need RMB 500,000 creates unnecessary obligations.
  • Mixing capital with personal funds: Registered capital must flow through the company's formal accounts. Personal transfers or side payments violate Chinese law and can result in penalties.
  • Using capital before registration is complete: Capital cannot be used before the bank account and FDI registration are finalized.
  • Forgetting to verify capital for special purposes: If you plan to apply for government projects or bank loans, obtain a capital verification report proactively.

Conclusion

China's subscribed capital system offers flexibility, but the 2024 Company Law reform requires more disciplined capital planning with a 5-year contribution deadline. Set your registered capital at a level that balances credibility, operational needs, and your ability to inject funds within the required timeframe. Proper capital management ensures smooth banking, tax compliance, and business credibility in China.

For help estimating your ideal registered capital based on your business plan, use our WFOE Cost Calculator.

Frequently Asked Questions

What is the minimum registered capital for a WFOE in China?
There is no universal legal minimum registered capital for most industries. You set the capital amount based on your operational needs. However, it must be realistic. Common ranges are RMB 100K-500K for consulting, RMB 500K-1M for trading, and RMB 1M-5M+ for manufacturing.
Do I need to pay in all the registered capital upfront?
No. China uses a subscribed capital system where you declare the capital amount and a contribution period (up to 30 years). You inject capital gradually as needed. However, banks and tax authorities may scrutinize companies with unrealistically long timelines or very low capital.
Can I use RMB as registered capital for a WFOE?
Registered capital for a WFOE must be injected in foreign currency (USD, EUR, etc.) from abroad and converted to RMB through a Foreign Exchange Capital Account. You cannot use RMB already held in China as the initial capital injection unless it meets specific SAFE requirements.
What happens if I over-inject capital?
Capital injected above the registered amount is treated as a capital reserve. It can be converted to registered capital through an amendment filing, or returned to the investor as a capital reduction (which requires a formal process and creditor notification).

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