The full process of overseas ODI filing for enterprises in 2026: how small and medium-sized enterprises can take the first step towards overseas investment after the implementation of the new policy

When many small and medium-sized enterprises consider overseas investment for the first time, the first problem they encounter is not "where to go", but "how to get there".

A manufacturing company with annual revenue of tens of millions wants to establish a trading company in Hong Kong to manage orders and supply chains in Southeast Asia. The financial manager looked around and found that he had to go to the National Development and Reform Commission, the Ministry of Commerce, and the State Administration of Foreign Exchange. He couldn't understand the list of materials and the cycle was uncertain. In the end, I had to ask someone repeatedly, not knowing where I was stuck.

This is a common situation faced by many companies preparing to go global in 2026. ODI (Overseas Direct Investment) filing is not a simple administrative procedure, it is the starting point for cross-border business compliance of enterprises. Filing cannot proceed, and subsequent fund transfers, bank account opening, and overseas structure construction will all be stuck.

1、 What exactly is ODI and why can't it be bypassed

Simply put, ODI is an investment behavior in which domestic enterprises acquire ownership or control of non-financial enterprises overseas through new establishment, mergers and acquisitions, and other means. According to current regulations, such investments need to be registered or approved by the development and reform department, commerce department, and foreign exchange management department.

Why do we need this set of procedures? Because it addresses two core issues: compliance, allowing regulators to know what funds are going for and where they are going; The second is the fund channel. Without filing documents, banks will not allow large amounts of funds to be remitted, and overseas accounts of enterprises are also difficult to operate normally.

For small and medium-sized enterprises, the value of ODI lies not in "running processes", but in being a passport for legalizing overseas business. With filing, enterprises can legitimately establish companies, sign contracts, and receive and pay foreign exchange overseas, rather than staying in the "trial and error" stage for a long time.

2、 What changes will the new policy bring in 2026

In October 2026, the National Development and Reform Commission announced the new "Measures for the Administration of Foreign Investment", which will come into effect on December 1, and the "Measures for the Administration of Enterprise Overseas Investment" of 2017 will be simultaneously abolished.

The new approach better guarantees the development and security of foreign investment at the institutional level. For the actual operation of enterprises, there are several changes worth paying attention to:

Firstly, the boundary between filing and approval is clearer. Sensitive projects still require approval, while non sensitive projects are subject to filing management. Before starting a business, it is necessary to determine which category its project belongs to in order to avoid going through the wrong window.

Secondly, there are higher requirements for the connection between departments. Development and Reform Commission filing, business filing, and foreign exchange registration are no longer three isolated links, but a chain that connects them before and after. Insufficient preparation of materials can easily lead to rejection at a certain stage, delaying the overall pace.

Thirdly, guidance for small and medium-sized enterprises should be more clear. Many companies used to not know where to start, but now comprehensive service platforms for companies going global are providing one-stop consultation to help them sort out materials and judge paths.

3、 Three common difficulties for small and medium-sized enterprises

In practical operation, small and medium-sized enterprises are most likely to get stuck in three areas during the ODI process.

The first challenge is architecture design. Many companies think that setting up a company directly in Hong Kong is enough, but in reality, they need to consider future financing, taxation, and profit return paths. The architecture design was wrong, and the cost of making changes later on is very high.

The second challenge is material preparation. Filing requires providing documents such as investment authenticity statement, proof of funding source, and analysis of overseas investment environment. These materials cannot be written casually. The regulatory authorities will focus on verifying whether the investment logic is reasonable and whether the source of funds is clear.

The third difficulty is cycle control. From initiation to obtaining the "dual certificates" (notification of development and reform filing and overseas investment certificate), it may take several weeks to several months if everything goes smoothly. If the materials are returned for supplementation, the cycle will be further extended. For enterprises that are already advancing their business, the time cost is high.

4、 How to determine whether you need professional services or not

Some small enterprises want to explore the ODI process on their own. This is not impossible, but it depends on several conditions:

If a company is making overseas investments for the first time and does not have a professional cross-border legal or financial team, it is recommended to rely on external service agencies. The reason is simple: the regulations and practical details involved in ODI are frequently updated, and the time cost for enterprises to conduct their own research often exceeds the cost of hiring professional agencies to handle it.

When choosing a service provider, several dimensions can be considered: whether there are successful cases of similar projects, whether they can provide full process services from architecture design to foreign exchange registration, and whether they are familiar with the latest policy guidelines.

5、 What problems can the Shanghai exhibition in November help enterprises solve

From November 20th to 22nd, 2026, the Shanghai World Trade Exhibition Center will host the Overseas Immigrant Study and Property Expo, as well as the Enterprise Overseas Development and Financial Services Expo. This exhibition will last for three days and is expected to attract around 8000 attendees.

For companies considering ODI filing and overseas architecture, the value of this exhibition lies in:

On site coordination with professional service agencies. There are service providers in the fields of ODI filing, cross-border compliance, and overseas architecture design at the exhibition. Enterprises can directly consult on-site to understand the service scope and pricing of different institutions, rather than searching online one by one.

Understand the latest policy guidelines. The new policy has just been implemented, and the implementation details may vary in different regions. The interpretation and communication of policies at the exhibition site can help companies understand the impact of new regulations on their projects more quickly.

One stop solution for shipping chain issues. In addition to ODI filing, going global for enterprises also involves bank account opening, foreign exchange management, tax planning, overseas company registration, and other processes. The exhibition covers these fields, and enterprises can complete multiple information connections in the same space.

Save decision-making time. It may take several months for companies to explore on their own, but spending one or two days at exhibitions can clarify key issues, compare service agencies, and directly move forward to the next step.

6、 What can participating companies gain

For participating service companies, this exhibition also has clear value:

Directly reach the target customers. Among the 8000 attendees, a considerable proportion are individual and corporate decision-makers who are making overseas decisions, identity planning, study abroad applications, or overseas asset allocation. This is more precise than advertising online.

Establish professional trust. At the exhibition site, face-to-face communication, case studies, and answering questions can be achieved, and this trust building method is irreplaceable by online communication.

Gain industry insights. Communicate with peers, customers, and potential partners to timely understand the latest market demands and policy changes, and adjust one's service direction.

Expand cooperation channels. Service agencies from different fields (such as ODI, immigration, study abroad, finance) can establish cooperative relationships at exhibitions, recommend customers to each other, and form a service loop.

In conclusion

ODI filing is not the end point for enterprises to go global, but the starting point. Once the filing process is completed, the subsequent overseas business can truly be implemented.

For small and medium-sized enterprises, the most important thing is not to "run the process smoothly on their own", but to "solve compliance issues in the shortest possible time and focus on the business itself". The Shanghai exhibition in November happened to provide such a centralized platform for communication and quick decision-making.

For exhibition consultation, please call 13681692751 (same as WeChat) or visit the official website www.qs-expo.com for more details. The exhibition will take place from November 20th to 22nd, 2026, at the Shanghai World Trade Exhibition Center.

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The full process of overseas ODI filing for enterprises in 2026: how small and medium-sized enterprises can take the first step towards overseas investment after the implementation of the new policy

Online Consultation

Online Registration

The full process of overseas ODI filing for enterprises in 2026: how small and medium-sized enterprises can take the first step towards overseas investment after the implementation of the new policy

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