2026 Enterprise Overseas ODI Filing Process: How Manufacturing and Trading Enterprises Take the First Step towards Compliance After the Implementation of New Regulations

On June 1, 2026, State Council Decree No. 837 promulgated the 'Regulations of the State Council on Outward Investment' and officially came into effect on July 1. This is a high-level and highly systematic administrative regulation in China's outbound investment field, consisting of 34 articles, which integrates the entire process of enterprise 'going global' service, management, and rights protection into a unified system.

For manufacturing, trade, and technology enterprises that are considering or have already started overseas layout, the signal conveyed by this new regulation is very clear: ODI (Overseas Direct Investment) is no longer just a filing process, but a full cycle compliance chain from project initiation, capital outflow, overseas company registration to embassy registration, and subsequent annual reports. Any chain failure at any stage may result in funding stagnation, project shutdown, or even freezing of overseas assets.

1、 What has the new regulation changed? Three key changes from the perspective of enterprises

Firstly, the regulatory logic has shifted from 'formal review' to 'substantive compliance'. In the past, when companies were filing for ODI, they often had to provide all the necessary documents and the bank's fund exit review was relatively relaxed. After the implementation of the new regulations, regulatory authorities and banks will focus on asking a few questions: What is the real business of your overseas projects? Where does the funding come from? To which country? Is it related to your main business? These issues are no longer just formalities, but the core of substantive examination.

Secondly, full cycle closed-loop control has become the norm. The new regulations not only regulate the filing process, but also extend to subsequent processes such as overseas company registration, bank account opening, fund remittance, profit return, and annual report updates. If a company thinks that everything will be fine once the case is filed, it is likely to be required by the bank to provide additional materials when the funds leave the country, or be listed as abnormal in the following year for not updating the filing information in a timely manner.

Thirdly, the industry's sensitivity has increased. In light of recent changes in the international investment environment, the scrutiny of ODI projects directed towards sensitive countries and industries has become increasingly stringent. Enterprises need to assess the geopolitical risks, foreign exchange control policies, and foreign investment access restrictions of the target country during the project initiation stage, rather than waiting until the materials are submitted to find that it is not feasible.

2、 Enterprises are most often stuck in these three places when going global

According to feedback from multiple cross-border service agencies, the bottlenecks encountered by enterprises in ODI implementation since 2026 are concentrated in three aspects.

One is the proof of project authenticity. Banks require enterprises to provide materials such as overseas investment contracts, feasibility study reports, and target company qualification certificates when handling fund remittances. Many small and medium-sized enterprises did not have a system to prepare these documents before, and the temporary supplementation of materials often delayed for one to two months.

The second is the design of the funding path. After the ODI filing is completed, funds are not automatically exported and need to be purchased and remitted through banks. The funding paths vary greatly depending on the amount, industry, and destination country. Some companies first exchange US dollars domestically and then transfer them out through other channels, which carries extremely high risks under the new regulations and is easily identified as illegal foreign exchange splitting and sales.

Thirdly, there is a gap in overseas landing services. After filing a case domestically, many companies do not know who to contact when registering a company, opening a bank account, doing tax registration, or finding a local accountant overseas. There is often an information gap between domestic service agencies and local resources overseas, resulting in a prolonged project implementation cycle.

3、 Cross border financial support: an easily overlooked aspect for overseas enterprises

ODI is just the first step, there is still a long list of financial issues to be resolved after the funds leave the country.

When enterprises obtain financing overseas, receive payments from overseas customers, or need to remit profits back to China, they all involve issues such as cross-border settlement, offshore account management, and exchange rate hedging. In June 2026, the People's Bank of China and six other departments jointly issued the 'Action Plan for the Development of Offshore Finance in Shanghai International Financial Center', which clearly proposes to support non resident individuals and enterprises in offshore wealth management, global asset allocation, family trust and other businesses. This means that the policy environment for Shanghai as an offshore financial hub is continuously improving, and the financial instruments available for overseas enterprises are much richer than in previous years.

But for most small and medium-sized enterprises, these policies and tools are still at the stage of being 'heard of'. How to open an offshore account, how to lock up exchange rate risks, and how to legally repatriate overseas profits all require one-on-one communication with professional financial institutions, which cannot be easily understood by just reading a few articles.

4、 November Shanghai Expo: One docking of ODI full chain resources

Against this backdrop, the 2026 Shanghai Overseas Immigrants, Study Abroad, Real Estate, and Enterprise Overseas and Cross border Cooperation Expo will be held from November 20th to 22nd at the Shanghai World Trade Exhibition Center for three days, with an expected attendance of about 8000 professional visitors.

For enterprises with overseas plans, the value of this exhibition lies not in 'watching the exhibition', but in meeting all the key service providers on the ODI chain in three days at once:

-ODI filing and legal consulting agency: can assess in person whether your project meets the requirements of the new regulations, pre review the list of materials, and reduce the time cost of sending and receiving supplementary documents;

-Cross border banks and offshore financial service providers: on-site consultation on offshore account opening, cross-border settlement solutions, exchange rate hedging tools, comparing rates and delivery times of different banks;

-Destination country landing service providers: including local resources such as overseas company registration, tax declaration, employment compliance, etc., suitable for deep docking with enterprises that already have a clear destination;

-Pioneers in the same industry going global: At the exhibition, there will be many entrepreneurs who have already set up factories or companies in Southeast Asia, the Middle East, and Europe, and can directly exchange their experience of stepping into pitfalls.

The core benefits of enterprises participating in such exhibitions can be summarized as three points: narrowing the information gap (no need to call one by one to ask), improving the efficiency of scheme comparison (meeting multiple service providers at the same venue, making preliminary judgments on the same day), and advancing the landing pace (many enterprises originally took six months from project approval to capital outflow, but through exhibition docking, it can be compressed to two or three months).

5、 Write at the end

The implementation of the new ODI regulations in 2026 is essentially forcing Chinese overseas enterprises to shift from 'wild growth' to 'standardized operation'. In the short term, the process of filing and capital outflow has indeed become more complex than before; But in the long run, compliant enterprises will actually reduce overseas asset risks in a more transparent regulatory environment.

For businesses on the road, the Shanghai World Trade Exhibition Center from November 20th to 22nd is a worthwhile event worth arranging for half a day to a day. Bring your project overview and chat with ODI lawyers, cross-border banks, and destination country service providers on site, which is more effective than making ten phone calls in the office.

Exhibition invitation and audience consultation hotline: 13681692751 (same as WeChat). Official website: www.qs-expo.com.