From Domestic Market to Global Layout: Why Do Enterprises Need ODI Filing for Going Global

When a domestic enterprise decides to establish a subsidiary overseas, acquire overseas enterprises, or make long-term equity investments, the first unavoidable procedure is ODI filing. The full name of ODI is Outbound Direct Investment, which refers to the act of Chinese domestic enterprises establishing enterprises overseas or acquiring ownership, control, management and other rights of existing enterprises through new establishment, mergers and acquisitions.

In the first half of 2026, Chinese companies' overseas investments showed significant structural changes. According to public data, Australia and Singapore remain the two top destinations of concern for Chinese companies, while the attention to emerging markets such as the Middle East, Central Asia, and Southeast Asia continues to rise. More and more manufacturing, technology, and trading companies are considering expanding their production capacity overseas, setting up research and development centers, or expanding their local markets.

However, many companies are not clear about the specific process, approval department, and timeline for ODI filing in the early stages of preparing to go global. Some companies mistakenly believe that they only need to register a company overseas, ignoring their domestic approval obligations; Some companies have missed the market window due to insufficient preparation of materials, resulting in a significant extension of the filing period.

Which departments are involved in ODI filing and what are they reviewing separately

ODI filing is not a single departmental approval process, but a collaborative process involving three core departments: the Ministry of Commerce, the National Development and Reform Commission, and the State Administration of Foreign Exchange. Understanding the audit focus of each of these three departments is a prerequisite for enterprises to successfully complete the filing process.

Filing with the business department is the first step. Enterprises need to log in to the unified platform of the Ministry of Commerce's business system and submit materials such as overseas investment filing forms, copies of business licenses, board resolutions, investment agreements, etc. Central enterprises are directly handled by the Ministry of Commerce, while local enterprises are handled by the provincial-level commerce department in their registered location. After approval, the enterprise will obtain the "Certificate of Overseas Investment".

Filing with the National Development and Reform Commission is the second line. The filing or approval authority of the National Development and Reform Commission varies depending on the investment amount and industry. Sensitive projects require approval, while non sensitive projects are subject to filing management. Large scale overseas investment projects also need to pay attention to the large scale reporting system of the National Development and Reform Commission.

Foreign exchange registration is the final step. After obtaining the filing documents from the Ministry of Commerce and the National Development and Reform Commission, enterprises need to go to the bank to handle foreign exchange registration for overseas direct investment before officially remitting funds overseas. After completing the foreign exchange registration, the enterprise still needs to fulfill the subsequent obligation of stock equity registration.

Overall, the regular processing cycle for newly established ODI projects is approximately two to three months, while for M&A projects involving due diligence and transaction structure design, the cycle is usually three to four months. If a company plans to complete its overseas layout by the end of 2026 or early 2027, it should start the preparatory work now.

Observation of popular destinations for enterprises going global in 2026

From the perspective of industry distribution, manufacturing enterprises have the strongest willingness to go global. Vietnam, Thailand, and Indonesia in Southeast Asia remain the preferred destinations for capacity transfer, as these countries not only have competitive labor costs but also enjoy relatively favorable trade agreement treatment.

For technology-based enterprises, Singapore and Dubai in the United Arab Emirates are two key cities worth paying close attention to. Singapore has a mature legal service system, a stable political environment, and a well-developed capital market, making it a suitable location for the Southeast Asian regional headquarters and research and development center; Dubai, relying on its free zone policy and Middle East market radiation capability, has become a springboard for many Chinese technology companies to enter the Middle East and African markets.

In addition, countries in Central Asia such as Kazakhstan and Uzbekistan have increasingly close ties with China in infrastructure construction and energy cooperation in recent years. Enterprises in the fields of construction engineering, energy equipment, and agricultural development are incorporating Central Asia into their overseas layout.

Common compliance risk points for enterprises going global

ODI filing is only the first step in going global, and subsequent compliance management is equally important. According to industry observations, the easiest steps for companies to take in the process of going global include:

Firstly, the investment architecture design is unreasonable. Some companies, in order to save time, directly register their companies overseas with domestic entities without considering tax planning and the convenience of future exits. A reasonable investment structure usually requires the establishment of appropriate holding platforms in the middle layer to optimize tax efficiency and risk isolation.

The second is to ignore the industry access requirements of the host country. The restrictions on foreign investment vary greatly among different countries, with some industries requiring local joint ventures and others requiring special permits. Before initiating ODI filing, enterprises should simultaneously understand the foreign investment access policies of the target country.

The third issue is the omission of subsequent annual reports and stock equity registration. Many companies think everything is fine after obtaining the certificate, but in fact, after completing the ODI filing, they need to complete the registration of existing equity and major event reports on time every year, otherwise it will affect the subsequent foreign exchange business processing.

Why choose to participate in this year's Overseas Expo

For companies preparing to go global, attending a professional industry exhibition can quickly connect with a large amount of resources and reduce information asymmetry. The Overseas Immigrant Study and Property Expo, as well as the Enterprise Overseas Development and Financial Services Expo, will be held at the Shanghai World Trade Exhibition Center from November 20th to 22nd, 2026. A special section for ODI enterprise overseas development will be set up, inviting representatives from business consulting agencies, law firms, accounting firms, banks, and overseas parks to attend.

There are several benefits that companies can gain from participating in or attending exhibitions. Firstly, on-site consultation on the specific process and material requirements for ODI filing can avoid taking detours; Secondly, connect with overseas parks and investment promotion agencies from different countries to directly understand the local policy environment and supporting services; Thirdly, engage in face-to-face communication with cross-border financial service institutions to plan in advance for the outflow of funds and subsequent foreign exchange management plans; Fourthly, exchange experiences with overseas enterprises in the same industry to understand the latest market trends.

This exhibition will last for three days and is expected to attract around 8000 attendees, including business owners, executives, legal and financial managers, as well as high net worth individual clients. No matter which stage of the enterprise's overseas planning, corresponding service resources can be found on site.

If you are considering matters related to your company's overseas expansion, please call the exhibition hotline 13681692751 (same as WeChat) to inquire about exhibition or viewing details. You can also visit the official website www.qs-expo.com to learn more about exhibition information.