Implementation Measures for the Establishment in Shanghai of Joint Partnerships Between Law Firms from the Hong Kong and Macao Special Administrative Regions and from the Chinese mainland

Chapter I  General Provisions

Article 1 (Purposes and Legal Basis)

With a view to regulating and promoting the orderly establishment in Shanghai Municipality (hereinafter referred to as "this Municipality" or "Shanghai") of joint partnerships between law firms from the Hong Kong Special Administrative Region and the Macao Special Administrative Region (hereinafter collectively referred to as "Hong Kong and Macao") and law firms from the Chinese mainland, and to further strengthening cooperation between the legal professions of Hong Kong, Macao, and the Chinese mainland, these Measures are formulated in accordance with the Notice of the State Council on Replicating and Promoting the Fourth Batch of Pilot Reform Experiences from Free Trade Zones (SC G [2018] No.12), the Reply of the State Council on Agreeing to Comprehensively Deepen the Pilot Programs for Innovative Development of Trade in Services (SC L [2020] No.111), the Notice of the Ministry of Justice on Expanding the Geographical Scope of Joint Partnerships Between the Law Firms from the Chinese mainland and from Hong Kong/Macao (MJ G N [2019] No.10), and the Notice of the General Office of the Ministry of Justice on Promoting the Pilot Programs for Comprehensive Deepening of Innovative Development in Trade in Services (MJ O N [2021] No.1), and in light of the actual circumstances of this Municipality.

Article 2 (Definition of Joint Partnership)

The "joint partnership" in these Measures refers to a partnership-type joint law firm (hereinafter referred to as the "joint law firm") established within the jurisdiction of this Municipality by one or more law firms from Hong Kong or Macao and a law firm from the Chinese mainland, which, in accordance with these Measures and based on the rights and obligations stipulated in their mutual agreement, provides legal services and assumes legal liability in its own name.

A joint law firm may be established in the form of a special general partnership.

Article 3 (General Requirements)

A joint law firm established in this Municipality by a law firm (or law firms) from Hong Kong or Macao with a law firm from the Chinese mainland to provide legal services shall comply with the laws, rules, regulations and supervisory provisions of the Chinese mainland, uphold the ethics and disciplinary standards of the legal profession, refrain from endangering national security, disrupting social order, or undermining the public interest, and be subject to supervision and guidance of the municipal judicial administrative authorities and the lawyers' association.

Article 4 (Implementation Authority)

The establishment and operation of joint law firms in this Municipality by law firms from Hong Kong and/or Macao and law firms from the Chinese mainland are governed by Shanghai Municipal Bureau of Justice (hereinafter referred to as "the Municipal Bureau of Justice") in accordance with these Measures.

Chapter II  Requirements for Establishing Joint Law Firms

Article 5 (Requirements for Law Firms from Hong Kong or Macao)

A law firm from Hong Kong or Macao that satisfies the following requirements may apply to establish a joint law firm:

1. The firm is duly registered and established under the law of Hong Kong or Macao, with its head office located in Hong Kong or Macao;

2. The firm has engaged in providing legal services in Hong Kong or Macao for no less than five years and holds the requisite professional qualifications to handle legal matters under the law of Hong Kong or Macao;

3. The firm has at least three licensed lawyers, and its sole proprietor or all partners are lawyers duly registered and licensed in Hong Kong or Macao; and

4. The firm has, within the three years preceding its application for establishing a joint law firm, not been subjected to any disciplinary sanctions imposed by the legal regulatory authorities of Hong Kong or Macao, nor has any of its representative offices in the Chinese mainland been sanctioned by the legal regulatory departments of the Chinese mainland.

Article 6 (Requirements for Law Firms from the Chinese mainland)

A law firm from the Chinese mainland that satisfies the following requirements may apply, in its own name, to establish a joint law firm:

1. The firm is a partnership law firm that has been established for more than five years;

2. The firm has at least 30 licensed lawyers;

3. The firm is headquartered in this Municipality, or is based in another province, autonomous region, or municipality directly under the Central People's Government but has already established a branch office in this Municipality; and

4. Neither the firm nor its Shanghai branch has, within the three years preceding the application for establishing a joint law firm, been subjected to any administrative penalties or disciplinary sanctions imposed by legal regulatory departments.

A branch office of a law firm may not independently apply as a party for establishing a joint law firm.

Article 7 (Name of Joint Law Firms)

The name of a joint law firm established by a law firm or law firms from Hong Kong or Macao and a law firm from the Chinese mainland shall consist of three components in the following order: "Trade Name for the Joint Law Firm + Shanghai + Joint Law Firm."

Article 8 (Capital Contribution to Joint Law Firms)

The total capital contribution made by all parties to a joint law firm may not be less than five million yuan, and the specific mode of contribution shall be determined through mutual consultation among the participating firms. Where a party to a joint law firm is a single law firm from Hong Kong or Macao, its share of capital contribution may not exceed 49%. Where a party to a joint law firm includes multiple law firms from Hong Kong or Macao, their combined contribution shall remain less than that of the law firm from the Chinese mainland.

The capital contribution of all parties to a joint law firm may be subscribed on a deferred payment basis, provided however, the actual paid-in capital shall be no less than 30% of the subscribed amount upon application for establishing the joint law firm, and the balance shall be fully paid within three years after the establishment of the joint law firm is approved.

Article 9 (Number of Lawyers)

The total number of lawyers in a joint law firm may not be fewer than 10. The number of lawyers seconded by each party and the number of those directly employed by the joint law firm may be determined through mutual consultation among the parties, provided that the total number of lawyers seconded by the participating Hong Kong or Macao law firms may not exceed the number of lawyers seconded by the law firm from the Chinese mainland. Each party to a joint law firm shall designate one lead lawyer from among its seconded lawyers to take primary responsibility for coordination.

Lawyers seconded by any party shall have no less than three years of professional practice experience and may not have been subjected to any administrative penalties or disciplinary sanctions imposed by legal regulatory departments within the two years preceding their secondment.

A person in charge of the joint law firm shall be appointed from among the lawyers seconded by the law firm from the Chinese mainland and must be consented to by all other participating parties.

Lawyers seconded by Hong Kong or Macao law firms shall be locally qualified lawyers in Hong Kong or Macao.

No lawyer of a joint law firm who is from Hong Kong, Macao, or a foreign jurisdiction may simultaneously be employed by a law firm from the Chinese mainland, holding a Chinese mainland Practice Certificate for Hong Kong and Macao Residents or acting as a legal consultant on Hong Kong/Macao laws, neither may any such lawyer serve concurrently as a representative in the dispatching law firm's representative office in the Chinese mainland or be employed by a foreign law firm in its representative office in China.

Article 10 (Office Premises)

A joint law firm shall maintain a fixed and independent office space for its operations.

Article 11 (Other Requirements)

Law firms from Hong Kong, Macao, and the Chinese mainland that intend to apply for establishing a joint law firm may each contribute their existing representative office or branch office located in Shanghai as part of their respective inputs into the joint law firm.

Where a law firm from Hong Kong, Macao, or the Chinese mainland contributes its representative office or branch office in Shanghai to the joint law firm, such representative office or branch shall, within 15 days after approval of the establishment of the joint law firm, apply for its deregistration in accordance with the relevant procedures.

During the operation of a joint law firm, the participating law firms from Hong Kong, Macao, and the Chinese mainland, together with the joint law firm itself, shall establish mechanisms for prevention and review of conflicts of interest.

Article 12 (Joint Law Firm Agreement)

All parties applying for establishing a joint law firm shall enter into a written joint law firm agreement. The agreement shall comply with the relevant laws of the Chinese mainland and these Measures, and shall reflect the genuine intentions of all parties.

The agreement shall specify, including: the name of each participating law firm; the proportion, amount, method, and schedule of capital contributions to be made by each participating law firm; the number of seconded and employed lawyers, as well as the person in charge of the joint law firm; the rights and obligations of each party; the decision-making and management mechanisms of the joint law firm; the methods of income distribution, cost-sharing, and liability allocation; the arrangements for the assignment of lawyers and support staff, as well as professional liability and social insurance coverage; the liability for breach of contract; the handling of assets, debts, and claims upon expiration or termination of the joint law firm; the method of dispute resolution; and the duration of the joint law firm as well as the conditions and procedures for its termination or extension.

The agreement may not stipulate that any party to the joint law firm enjoys a decision-making power over major matters in a way exceeding its proportion of capital contribution.

The minimum duration of a joint law firm agreed upon by the parties may not be less than three years.

The joint law firm agreement shall take effect from the date on which the establishment of the joint law firm is approved.

Article 13 (Articles of Association of Joint Law Firms)

A joint law firm shall formulate Articles of Association which shall set forth the following matters and may not contravene the joint law firm agreement:

1. the name, principal person-in-charge, and registered domicile of the joint law firm;

2. the name of each participating law firm of the joint law firm;

3. the organizational form of the joint law firm;

4. the scope of practice of the joint law firm;

5. the proportion, amount, method, and schedule of capital contribution to be made by each participating law firm;

6. the rights and obligations of each participating law firm;

7. the arrangements for each party's secondment of lawyers and for the employment of lawyers and support staff by the joint law firm;

8. the decision-making and management mechanisms of the joint law firm;

9. the duties and responsibilities of the principal person-in-charge of the joint law firm and the procedures for appointment and replacement thereof;

10. the methods for income distribution, cost-sharing, and liability allocation among the parties to the joint law firm;

11. the systems governing the joint law firm's financial management, personnel management, professional liability insurance, and social insurance;

12. the procedure for disposal of assets, claims, and debts upon expiration or termination of the joint law firm;

13. the conditions and procedure for modification or termination of the joint law firm;

14. the procedure for amending the Articles of Association of the joint law firm;

15. the duration of the joint law firm and the procedure for its renewal; and

16. any other relevant matters.

The Articles of Association shall take effect from the date the establishment of the joint law firm is approved.

Chapter III  Procedure for Establishing Joint Law Firms

Article 14 (Application for Establishing Joint Law Firms)

Upon application, the parties intending to establish a joint law firm shall jointly submit the following materials to the bureau of justice in the district where the proposed law firm will be established :

1. an application statement jointly signed by the parties to the proposed joint law firm;

2. a joint law firm agreement jointly signed by the parties to the proposed joint law firm;

3. Articles of Association of the proposed joint law firm jointly signed by the parties;

4. valid documentary evidence proving that each participating law firm meets the requirements set forth in these Measures;

5. a list of lawyers of the joint law firm, together with valid proof that they meet the requirements set forth in these Measures, and the name of the proposed principal person-in-charge of the joint law firm along with the evidence proving his/her professional experience; and

6. proof of subscribed share of capital contribution by all parties to the joint law firm and proof of the domicile of the joint law firm.

Where a law firm from Hong Kong or Macao submits documentary proof as required by Items 4 and 5 in the preceding Paragraph, the documents must be notarized by a notary public or notarial institution recognized in the Chinese mainland.

All application materials shall be prepared in simplified Chinese and in triplicate. Any materials in a foreign language shall be accompanied by Chinese translation.

Article 15 (Examination and Approval Procedure)

The bureau of justice in the district where a proposed joint law firm is to be established shall, within 20 days from the date of receiving the application materials for establishing a joint law firm, make and submit recommendations to the Municipal Bureau of Justice. The Municipal Bureau of Justice shall, within 10 days of receiving the materials submitted by the district bureau, make a decision to approve or deny the application for establishing a joint law firm. Where it is not possible to make a decision within such period, an extension of up to 10 days may be made upon approval by the head of the same administrative authority, and the applicant shall be informed in writing of the grounds for extension.

For an application that meets the requirements of these Measures, approval shall be granted, a Practice License shall be issued, and the approval documents as well as the other relevant materials shall, within 30 days after the decision is made, be filed to the Ministry of Justice for record. For an application that does not meet the requirements of these Measures, it shall be denied and the applicant shall be notified in writing.

For a lawyer of a joint law firm who is from the Chinese mainland, the Municipal Bureau of Justice shall, by reference to the management rules applicable to lawyers in a branch office of a law firm, reissue a lawyer practicing license listing the joint law firm as his/her associated firm, replacing the old one. For a lawyer of the joint law firm who is from Hong Kong or Macao, the Municipal Bureau of Justice shall issue a Hong Kong/Macao Lawyers' Work Permit associated with the joint law firm.

Article 16 (Preparations for Opening)

A joint law firm shall open for business within six months from the date on which the Municipal Bureau of Justice grants approval for its establishment. Before opening for business, a joint law firm shall, in accordance with relevant provisions, complete all necessary preparatory procedures, including seal engraving, capital contribution, bank account opening, tax registration, and work permit processing for Hong Kong and Macao lawyers practicing in the Chinese mainland. The specimen seals (official and financial) and bank account information of the joint law firm shall be submitted to the Municipal Bureau of Justice through the bureau of justice in the district where the joint law firm is established.

Article 17 (Modification and Record Filing Procedure)

Where the parties to a joint law firm decide to change the principal person-in-charge, the entity name, the Articles of Association, or the joint law firm agreement, or to replace, assign more, hire, or dismiss lawyers, they shall submit an application for modification in the name of the joint law firm to the bureau of justice in the district where the joint law firm is established, together with the relevant supporting materials. The application shall, after being reviewed by the local bureau of justice, be submitted to the Municipal Bureau of Justice for approval, and the relevant modification procedures shall be duly followed.

Where a joint law firm changes its registered domicile, it shall, within 15 days from the date of change, file for record with the Municipal Bureau of Justice through the bureau of justice in the district where the joint law firm is established.

Where any party or any one of the parties to a joint law firm changes its entity name or organizational form, or undergoes division or merger, it shall, within 30 days from the date of such change, file for record with the Municipal Bureau of Justice through the bureau of justice in the district where the joint law firm is established.

Article 18 (Record Filing for Renewal)

Where the parties to a joint law firm resolve to extend the duration of the joint law firm prior to expiration of its term, the resolution documents shall be filed for record with the Municipal Bureau of Justice through the bureau of justice in the district where it is established no later than 15 days before its expiration date.

Article 19 (Termination of Joint Law Firms)

A joint law firm shall be terminated under any of the following circumstances:

1. The requirements for its establishment prescribed in these Measures are no longer satisfied, and the situation exists after a prescribed period for rectification;

2. It fails to open for business within six months from the date of approval by the Municipal Bureau of Justice, or it has suspended its business activities for one year or more;

3. Upon expiration of the partnership term, a resolution is made by all parties not to renew the joint law firm;

4. An event occurs which terminates the joint law firm as stipulated in the joint law firm agreement, or all parties make a joint resolution to voluntarily dissolve it;

5. The practice license of the joint law firm is revoked in accordance with law;

6. Any or any one of the parties to the joint law firm is terminated or fails to satisfy the requirements provided in these Measures, and the situation exists after the prescribed period for rectification; or

7. There exists any other circumstance where termination is required by any law or administrative rule.

Upon occurrence of any event leading to its termination, a joint law firm shall carry out liquidation in accordance with the Administrative Measures for Law Firms, lawfully handle the matters such as asset distribution and debt settlement, and file for deregistration to the Municipal Bureau of Justice through the bureau of justice in the district where the joint law firm is established.

Chapter IV  Rules Governing Joint Law Firms

Article 20 (Scope of Practice of Joint Law Firms)

A joint law firm may accept and handle all categories of litigation cases other than criminal cases, and civil or commercial non-litigation legal matters.

Article 21 (Scope of Lawyers' Practice)

The scope of practice area of a lawyer associated with a joint law firm shall be in compliance with the laws, rules and regulations of the Chinese mainland. The scope of practice area of a lawyer from the Chinese mainland associated with a joint law firm is governed by the provisions of the Law of the People's Republic of China on Lawyers and the Administrative Measures for the Practice of Lawyers. The scope of practice area of a lawyer from Hong Kong or Macao associated with a joint law firm is governed by the Administrative Measures for the Representative Offices of Hong Kong and Macao Law Firms in the Chinese mainland, and such lawyers may not handle cases relating to the laws of the Chinese mainland.

Article 22 (Division of Legal Practice Among Lawyers)

A joint law firm accepts and manages all legal matters in its own name. A legal matter involving the law of the Chinese mainland shall be handled by the lawyers from the Chinese mainland, while a legal matter involving Hong Kong or Macao law shall be handled by Hong Kong or Macao lawyers. For a matter involving both the law of the Chinese mainland and the law of Hong Kong or Macao, lawyers shall cooperatively handle the matter according to their respective authorized scopes of practice. For a matter involving application of a foreign law, particularly involving application of an international treaty or international customary law, lawyers from all parties shall work in collaboration.

Article 23 (Prevention of Conflicts of Interest)

A lawyer seconded by any participating law firm or employed by the joint law firm, and a lawyer associated with any participating law firm may not represent or provide legal services to clients with conflicting interests in a same civil or commercial litigation, non-litigation, or administrative proceeding.

Article 24 (Professional Qualifications)

Upon assessing the professional qualification of a joint law firm providing services in the Chinese mainland, the number of years of establishment, professional performance, and other qualifications of its participating law firms from Hong Kong, Macao, and the Chinese mainland may be jointly used as the basis for assessment.

Article 25 (Service Fee Charge)

In conducting its business activities, a joint law firm shall collect legal service fees from clients in its own name in a unified manner. For a matter governed by the law of the Chinese mainland, fees shall be charged in accordance with the provisions and standards of the Chinese mainland on administration of legal service fees. For a matter governed by the law of Hong Kong or Macao, fees shall be charged in accordance with the standards or prevailing practice applicable in Hong Kong or Macao. For a foreign-related legal matter, fees may be determined through consultation with the client.

All business-related fees of a joint law firm shall be settled within the territory of the Chinese mainland.

Article 26 (Financial Management)

A joint law firm shall establish a unified financial management and accounting system. The methods for income distribution, cost sharing, remuneration and benefits for lawyers and other staff, social insurance arrangements, and the establishment of any relevant funds shall be implemented in accordance with the provisions of the joint law firm agreement and the Articles of Association.

Joint law firms shall pay taxes in accordance with law.

Article 27 (Employment of Personnel)

A joint law firm may hire lawyers according to its business needs. Upon hiring, a lawyer from the Chinese mainland may be hired either in the name of the participating law firm from the Chinese mainland and then designated as a seconded lawyer, or in the name of the joint law firm as a directly employed lawyer. Likewise, a lawyer from Hong Kong or Macao may be hired either in the name of the participating law firm from Hong Kong or Macao and then designated as a seconded lawyer, or in the name of the joint law firm. A foreign lawyer registered in Hong Kong shall be hired in the name of the participating law firm from Hong Kong, and be designated as a seconded lawyer.

A joint law firm may enroll trainee lawyers who apply for legal internships, and may employ assistants, secretaries, and other support staff. Upon hiring personnel from the Chinese mainland, the firm shall comply with the provisions of the Labor Contract Law of the People's Republic of China. Upon hiring overseas personnel, the firm shall also comply with the relevant provisions of the Chinese mainland.

Article 28 (Professional Liability Insurance)

A joint law firm shall establish a system of professional liability insurance for its lawyers. In accordance with the agreement among the parties to the joint law firm, such insurance may be purchased collectively in the name of the joint law firm, or separately by each participating law firm in its own name. For a participating law firm from Hong Kong or Macao that purchases professional liability insurance in Hong Kong or Macao, the scope of coverage of such insurance shall be extended to cover their lawyers' practice activities in the Chinese mainland. The amount of insurance coverage shall be determined through consultation among all parties to the joint law firm.

Article 29 (Sharing of Responsibilities and Liabilities)

Where a joint law firm or one of its lawyers causes losses to a client as a result of an illegal act or professional misconduct, the joint law firm shall bear liability for its debts in accordance with the statutory liability mechanism for a special general partnership. The apportionment of liability among the participating law firms shall be determined based on that mechanism and in accordance with the provisions of the joint law firm agreement.

Article 30 (Management Structure)

The person in charge of a joint law firm shall perform duties and responsibilities of management of the firm's business activities and internal affairs.

A joint law firm may establish a management committee, with the members selected from among the lawyers seconded by each participating law firm. The powers, responsibilities, and rules of procedure of the management committee shall be stipulated in the Articles of Association.

Article 31 (Internal Management Systems)

A joint law firm shall, in accordance with the Law of the People's Republic of China on Lawyers and the relevant administrative regulations, establish and improve its internal management systems, including management systems of lawyers' professional practice, conflict of interest review, risk prevention in legal practice, fee collection and financial management, personnel and remuneration management, handling of complaints and disciplinary matters, annual inspection and assessment, and archives management. A joint law firm shall supervise the compliance of its employed lawyers as well as the lawyers seconded by the participating law firms with professional ethics and practice discipline during their performance of professional activities.

Article 32 (Supervision and Consultation Mechanisms)

The law firms participating in a joint law firm shall, in accordance with the joint law firm agreement, supervise the operations of the joint law firm and the professional conduct of its lawyers, and establish a joint consultation and decision-making mechanism for major matters of the firm, ensuring timely communication and coordinated resolution of issues arising during the course of the partnership.

Chapter V  Supervision and Administration

Article 33 (Regulatory Authorities)

The Municipal Bureau of Justice shall, in accordance with these Measures, exercise supervision and administration over joint law firms established by law firms from Hong Kong or Macao and law firms from the Chinese mainland, and shall guide the bureaus of justice in the districts where joint law firms are established in carrying out routine supervision of the professional activities of the joint law firms within their jurisdictions.

Shanghai Bar Association shall conduct disciplinary management of the professional conduct of the joint law firms and their lawyers.

Article 34 (Joining the Bar Association)

The lawyers of a joint law firm who are from the Chinese mainland shall join Shanghai Bar Association as regular members. The lawyers of a joint law firm who are from Hong Kong or Macao shall join Shanghai Bar Association as special (invited) members, participate in its activities, and be subject to its supervision and guidance, with their rights and obligations governed by the rules applicable to special members.

A joint law firm shall join Shanghai Bar Association as an institutional member.

Article 35 (Annual Inspection and Assessment)

A joint law firm shall, during the first quarter of each calendar year, submit the following materials to the bureau of justice in the district where it is established for the purpose of accepting annual inspection and assessment by the judicial administrative authorities:

1. a summary report on the firm's legal service activities during the preceding year;

2. the annual financial statements of the joint law firm audited by an accounting or auditing firm, together with proof of tax payments made in accordance with law;

3. information regarding changes in the lawyers seconded by the participating law firms, and employed lawyers and other staff of the joint law firm, as well as any significant changes concerning the joint law firm; and

4. any other matters related to the implementation of these Measures.

Article 36 (Assessment Results)

The bureau of justice in the district where a joint law firm is established shall review the summary report and relevant materials submitted by the joint law firm and prepare and submit a review opinion to the Municipal Bureau of Justice. The Municipal Bureau of Justice shall, in accordance with the Measures for the Annual Inspection and Assessment of Law Firms, conduct annual inspection and assessment of the joint law firm and evaluate its professional practice and management performance.

A joint law firm shall, under the guidance of Shanghai Bar Association, conduct annual assessment of the professional performance of the lawyers seconded by the participating law firms and the employed lawyers by reference to the Rules on the Annual Assessment of Lawyers' Practice.

Article 37 (Handling of Violations and Unlawful Conduct)

Where a joint law firm is found to have violated any law, rule or regulation, or significant deficiencies are found in the law firm's internal management during the annual inspection and assessment or in the course of routine supervision, the bureau of justice in the district where the joint law firm is established shall order the firm to make rectifications or, where circumstance is serious, impose appropriate administrative penalties in accordance with the Law of the People's Republic of China on Lawyers and the Measures for the Imposition of Administrative Penalties on Lawyers and Law Firms for Unlawful Acts.

Where an unlawful act is committed by a lawyer of a joint law firm who comes from the Chinese mainland, the lawyer shall receive administrative penalties under the Law and Measures mentioned in the preceding Paragraph. Where an unlawful act is committed by a lawyer of a joint law firm who comes from Hong Kong or Macao, the lawyer shall receive penalties by reference to the Administrative Measures for the Representative Offices of Hong Kong and Macao Law Firms in the Chinese mainland.

Where a lawyer of a joint law firm who is from the Chinese mainland commits any act in violation of professional ethics or disciplines, the lawyer shall receive disciplinary sanctions imposed by  Shanghai Bar Association. Where a lawyer of a joint law firm who is from Hong Kong or Macao commits any of such misconduct, Shanghai Bar Association may recommend that the relevant professional organizations in Hong Kong or Macao impose appropriate disciplinary sanctions.

Article 38 (Support and Facilitation)

The Municipal Bureau of Justice, the bureaus of justice in the districts where joint law firms are established, and Shanghai Bar Association shall provide the joint law firms with policy and legal consultation services related to the Chinese mainland as well as comprehensive support necessary for the operation of the joint law firms, and coordinate with the relevant competent departments to facilitate the participating law firms and their seconded lawyers in matters such as work arrangements, customs clearance, office premises, residence, and taxation.

Chapter VI  Supplementary Provision

Article 39 (Date of Implementation)

These Measures shall be valid for a period of five years and shall take effect as of July 1, 2025.