Any Chinese mainland company making direct overseas investment — setting up subsidiaries, acquiring stakes, or funding overseas projects — generally needs ODI filing. Sensitive industries and destinations over USD 300 million require approval rather than simple filing.
ODI filing applies to Chinese mainland enterprises establishing or acquiring overseas entities: wholly-owned subsidiaries, joint ventures, M&A targets, or offshore project companies. Sensitive destinations (countries under sanctions, war zones) and sensitive industries (real estate, hotels, cinema, sports clubs,crypto mining) require case-by-case approval instead of simple filing. Pure equity-investment funds through QDLP/QDII channels follow different rules. Individual shareholders investing abroad do NOT use ODI — they use Article 37 (SAFE) registration instead. If your structure mixes corporate and individual shareholders, both tracks must be coordinated.
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