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Recent requirements for “Real-Name Authentication” in China

According to the new regulation recently promulgated by the State Administration for Market Regulation, a real-name authentication is imposed on those individuals who are in the following (but not limited to) positions in the process of establishment, change, filing, or deregistration of an enterprise:

  • Legal Representative;
  • Person in-charge;
  • Individual shareholder;
  • Director;
  • Supervisor;
  • Senior management personnel (including but not limited to General Manager, and Finance Person-In-Charge);
  • Contact officer with the registration authority;
  • Receiver for service of legal documents of foreign investors;
  • Designated Representative or Entrusted Agent.


Chinese citizens shall go through the real-name authentication with a face recognition procedure on the mobile app designated by the registration authority.  Foreign nationals shall have the real-name authentication done in person at the counter of the local registration authority in China with valid original passports.

As an alternative, for those who cannot complete the real-name authentications on the mobile app or at the counter of the local registration authority, an original authenticated document certified by the embassy and consulate of China in the country (or region) for the photocopy of the passport shall be submitted.

The above regulation applies to every commercial entity. For those who take positions in different companies shall carry out the real name authentication of each position for each company respectively.

Real-name authentication at the counter of the local registration authority can ONLY be made upon the onsite application submission. Early or late counter service of such authentication at the counter is unavailable.

In case of change of the above-mentioned position(s), the new-appointed personnel shall go through the real name authentication. Please note that the local authority may have its own requirements for verifying the authenticity of the applications for relevant matters.  Such as, a real-name authentication of the former legal representative shall be made when the legal representative is replaced.

Requirements may differ between local registration authorities when it comes in practice.  The exact implementation shall always refer to the corresponding authority in charge of the registration matters of your business entity in China.

On a related note, if you have a holding entity in Hong Kong, check whether the New Inspection Regime concerning restricted disclosure of personal data is applicable.

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