There is no statutory minimum for ODI filing — even small overseas investments must be registered. However, very small investments (under USD 1 million equivalent) still require the same three-step filing, just with lighter documentation.
Chinese regulations set no minimum threshold for ODI: any outbound direct investment, regardless of amount, requires NDRC, MOFCOM, and SAFE-bank registration. In practice, small investments under USD 1 million move faster with simplified feasibility documentation. What matters is proportionality: the investment amount should be consistent with the investor's financial capacity. A RMB 5 million company investing USD 50 million will trigger questions regardless of paperwork quality. Note that forming an overseas entity without transferring funds still has reporting implications — consult a professional before structuring.
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