Basic Information

Service

Processing of applications of overseas accounting firms for temporary audit licensing in the Chinese Mainland

Matter

Overseas accounting firms to temporarily perform auditing services in the Chinese mainland (new application)

Legal provisions

Interim Provisions on Overseas Accounting Firms' Temporary Performance of Auditing Services in the Chinese Mainland

Article 2: The scope of temporary auditing practice shall be strictly limited to engagements commissioned by overseas clients. Reports from such practice shall have no legal effect in the Chinese mainland. Overseas accounting firms and their certified public accountants are prohibited from undertaking services that, according to Chinese laws and regulations, are exclusively reserved for domestic accounting firms and their certified public accountants.

Article 5: Overseas accounting firms, overseas clients, and relevant domestic institutions shall be fully responsible for the truthfulness and completeness of the aforementioned application documentations.

Applicability

This guide is applicable to the processing of overseas accounting firms' applications for temporary audit licensing in the Chinese mainland.

Type of service  Administrative licensing

Authority  Shanghai Municipal Finance Bureau

Level  Municipal (provincial level)

Statutory requirements

1. Paragraph 2, Article 44 of the Law of the People's Republic of China on Certified Public Accountants

A foreign accounting firm that needs to temporarily conduct related business within China shall obtain approval from the finance authority of the people's governments of the provinces, autonomous regions, or municipalities directly under the Central Government.

2. Article 3 of the Interim Provisions on Overseas Accounting Firms' Temporary Performance of Auditing Services in the Chinese Mainland

An overseas accounting firm seeking to engage in temporary auditing practice within the Chinese mainland shall submit a written application to the provincial-level finance authority holding jurisdiction over the locality where the temporary auditing practice is to be conducted. If an overseas accounting firm seeks to undertake temporary auditing practice across two or more provincial-level administrative regions within the Chinese mainland, the firm shall submit its application to the Ministry of Finance of the People's Republic of China. Upon securing the requisite approval from the relevant finance authority and being duly issued a temporary auditing practice license, the overseas accounting firm shall be authorized to commence its temporary auditing practice within the Chinese mainland.

3. Article 1 of the Notice of the Ministry of Finance on Delegating Approval Authority for Overseas Accounting Firms' Temporary Performance of Auditing Services in the Chinese mainland

An overseas accounting firm seeking to engage in temporary auditing practice within the Chinese mainland shall submit a written application to the provincial-level finance authority holding jurisdiction over the locality where the temporary auditing practice is to be conducted. In the event that an overseas accounting firm seeks to engage in temporary auditing activities across two or more provincial-level administrative regions, the firm shall have the discretion to select and submit its application to one of the provincial-level finance authorities among those jurisdictions.

Implementing entity  Shanghai Municipal Finance Bureau

Nature of implementing entity  Statutory authority

Source of power  Law

Co-implementing entity  None

Target of service  Corporate legal persons and other organizations

Target of Approval/Confirmation/Payment/Levy/Reward/Service/Arbitration

Overseas accounting firms applying for temporary audit licensing in Shanghai Municipality or involving multiple provincial-level administrative regions including Shanghai.

Division of authority

1. Shanghai Municipal Finance Bureau is responsible for processing applications submitted by overseas accounting firms seeking a temporary license to perform auditing services within the administrative jurisdiction of Shanghai Municipality or across multiple provincial-level administrative jurisdictions, including Shanghai. This includes application review, decision-making and service of decision documents.

2. The Accounting Division of the Shanghai Municipal Finance Bureau is responsible for reviewing such applications.

Content

Overseas accounting firms to seek a temporary license to perform auditing services within the administrative jurisdiction of Shanghai Municipality or across multiple provincial-level administrative jurisdictions, including Shanghai.

Authorization

Upon securing the requisite approval, an overseas accounting firm shall be legally authorized to perform temporary auditing services within the administrative jurisdiction of Shanghai Municipality or across multiple provincial-level administrative jurisdictions, including Shanghai.

Quantity limit  No

Requirements concerning application materials

Application materials shall be deemed complete and in compliance with the statutorily prescribed format. For a comprehensive list of the required application materials, please refer to the List of Required Application Materials annexed to this Guide.

Requirements concerning applicants

1. The applicant shall be an accounting firm registered in the Hong Kong SAR, Macau SAR and Taiwan region of China, or a foreign country.

2. The applicant shall be an overseas accounting firm, under the engagement of an overseas client, to undertake the temporary auditing of a company or other pertinent entity established within the Chinese mainland.

Application deadline  None

Review deadline  5 working days

Processing method  Commitment

Statutory processing time limit  20 working days

Notes to statutory processing time limit

A decision shall be made to grant or withhold approval of the application within 20 working days from the date of acceptance of the application. If a decision cannot be made within the stipulated time limit, the time limit may be appropriately extended with the approval of the head of the finance authority, but the extension shall not exceed 10 working days.

Committed processing time limit  8 working days

Notes to committed processing time limit

A decision shall be made to grant or withhold approval of the application within 8 working days from the date of acceptance of the application.

Regular procedures

1. Receiving the application. Applicants may submit the requisite application materials via courier services.

2. Accepting the application. Shanghai Municipal Finance Bureau shall conduct a thorough examination of the application documentations submitted by the applicant. If the application materials are found to be incomplete or fail to adhere to the statutorily prescribed format, the Bureau shall, either immediately upon submission or within 5 working days thereof, provide the applicant with a single, comprehensive notification detailing all aspects of the application that require supplements or corrections. If the application materials submitted are complete and meet statutory format requirements, or if the applicant has made all supplements and corrections as required, the application shall be accepted. Shanghai Municipal Finance Bureau shall issue a written acknowledgment of receipt to the applicant, bearing the official seal of the Finance Bureau and the date of receipt, regardless of whether the application is ultimately accepted or rejected.

3. Reviewing the application. Shanghai Municipal Finance Bureau shall conduct a substantive review of the contents of the application materials submitted by the applicant.

4. Making the decision. Shanghai Municipal Finance Bureau shall make its decision to grant or withhold approval of the application within 8 working days from the date of acceptance of the application. If the situation is complex and a decision cannot be made within the prescribed time limit, with the approval of the head of the Bureau, the time limit may be appropriately extended and the applicant shall be informed. However, the extension shall not exceed 8 working days.

5. Service of decision documents. If Shanghai Municipal Finance Bureau makes a decision to grant approval of the application, the Bureau shall, within 10 working days from the date of the approval decision, issue to the applicant the requisite approval document and the "Temporary Auditing Practice License for Overseas Accounting Firms." Furthermore, the Bureau shall publish a public notice announcing the granting of such approval and the issuance of the aforementioned license. If a decision is made to withhold approval, Shanghai Municipal Finance Bureau shall, within 10 working days from the date of the decision, serve the written notice of denial upon the applicant. The written notice of denial shall specify the grounds for withholding approval and inform the applicant of their right to seek administrative reconsideration or institute administrative litigation in accordance with the applicable laws and regulations.

Special procedures  None

Scope of integrated government services  Shanghai Municipality

Operating system  National level

Charge or no charge  No

Intermediary service  None

Title of application document

Application Form for Overseas Accounting Firms to Temporarily Perform Auditing Services in the Chinese Mainland

Format requirements

1. Application materials shall be complete and sequenced in the order as set out in the list of required application materials;

2. The application form shall be filled out clearly and completely;

3. Electronic application materials submitted online shall be consistent with the hard-copy materials submitted in person;

4. Application materials shall be signed and stamped with the seal of the applicant or the applicant organization.

Instructions for preparing application materials

Application materials shall be prepared and submitted in Chinese. If the application materials are translated from foreign languages into Chinese, the original text shall also be provided.

Rights of applicants

Citizens, legal persons, or other organizations shall have the right to apply for administrative licensing in accordance with the law; applicants who meet the statutory requirements shall have equal rights to administrative licensing; applicants shall also have the right to make statements regarding administrative licensing review by administrative authorities, the right to defend themselves, and the right to supervision and remedies in accordance with the law.

Obligations of applicants

Citizens, legal persons or other organizations that need to undergo administrative approval to engage in specific activities according to the law shall apply for administrative approval in accordance with the law. Applicants shall truthfully submit relevant materials and reflect the actual situation, bearing full responsibility for the authenticity of the substantial content of their application materials. Applicants shall also fulfill the obligation to cooperate in the administrative approval process and accept supervision and inspection.

Acceptable ways to submit applications  In-person, online, or by mail

In-person reception address  Room 1711, 800 Zhaojiabang Road, Xuhui District, Shanghai

Online reception website  http://acc.mof.gov.cn

Mail reception address

Shanghai Municipal Finance Bureau, Room 1711, 800 Zhaojiabang Road, Xuhui District, Shanghai 200030

Business hours

Monday to Friday (except national holidays), 9:00-11:30 and 13:30-17:00 (summer: 14:00-17:00)

Forms of consultation  In-person, telephone, online, and mail

Consultation address  Room 1711, 800 Zhaojiabang Road, Xuhui District, Shanghai

Phone consultation numbers  (021) 54679568-17118; (021) 12345

Online consultation  https://www.czj.sh.gov.cn/shcz/hdjl/hd010_hdjl_zsly.jsp

Mail consultation address

Accounting Division of Shanghai Municipal Finance Bureau, Room 1711, 800 Zhaojiabang Road, Xuhui District, Shanghai 200030

Complaint channels  In-person, telephone, online, or mail

Address

Public complaints and proposals office of Shanghai Municipal Finance Bureau: 800 Zhaojiabang Road, Xuhui District, Shanghai

Hotline  (021) 12345

Website  http://wbjxf.sh.gov.cn/310000W0014

Mail address

Public Complaints and Proposals Office of Shanghai Municipal Finance Bureau, 800 Zhaojiabang Road, Xuhui District, Shanghai 200030

An example of common mistakes and corrections

Common mistake: The Application Form lacks the requisite signature of the duly authorized representative of the applicant accounting firm.

Proposed correction: The applicant accounting firm shall ensure that the Application Form is completed accurately. The duly authorized representative of the applicant accounting firm shall affix their signature to the completed Application Form.

Application Materials Required by Shanghai Municipal Finance Bureau For Overseas Accounting Firms to Temporarily Perform Auditing Services in the Chinese Mainland

No.	Name	Type	Form	Necessary or not	Source	Required copies	Requirements	Sequence order
1	Photocopies of the valid practicing licenses of the CPAs to be assigned to the engagement, as well as photocopies of legally recognized identification documents of any other relevant overseas personnel involved in the proposed auditing activities	Photocopy	Hard copy	Necessary	Applicant	1	The applicant shall bear full responsibility for the veracity and authenticity of the submitted materials.	7
2	Information sheet of CPAs to be assigned to the engagement and other relevant overseas personnel	Original	Hard copy	Necessary	Applicant	1	The applicant shall bear full responsibility for the veracity and authenticity of the submitted materials.	3
3	Photocopy of the confirmation letter issued by the relevant domestic entity, formally acknowledging and consenting to the temporary engagement of the overseas accounting firm to perform the proposed auditing activities in the Chinese mainland	Photocopy	Hard copy	Necessary	Applicant	1	The applicant shall bear full responsibility for the veracity and authenticity of the submitted materials.	6
4	Application Form for Overseas Accounting Firms to Temporarily Perform Auditing Services in the Chinese Mainland	Original	Hard copy	Necessary	Applicant	1	The applicant accounting firm shall bear full responsibility for the veracity and authenticity of the submitted application materials. The duly authorized representative of the overseas accounting firm shall affix their signature to the application documents and ensure that the official seal of the accounting firm is properly applied to the required materials.	1
5	Photocopy of the duly executed letter of engagement issued by the overseas client	Photocopy	Hard copy	Necessary	Applicant	1	The applicant shall bear full responsibility for the veracity and authenticity of the submitted materials.	5
6	Information sheet of the overseas client and relevant domestic entities	Original	Hard copy	Necessary	Applicant	1	The applicant shall bear full responsibility for the veracity and authenticity of the submitted materials.	2
7	Photocopies of the valid practicing license and the current business registration certificate issued by the competent authorities in the overseas accounting firm's country or region	Photocopy	Hard copy	Necessary	Applicant	1	The applicant shall bear full responsibility for the veracity and authenticity of the submitted materials.	4

FAQs Regarding Overseas Accounting Firms' Applications for Temporary Audit License in the Chinese Mainland

What types of overseas accounting firms are included?

For the purpose of this guide, "overseas accounting firms" refer to accounting firms established in Hong Kong SAR, Macao SAR and Taiwan, and foreign countries.

Does the temporary auditing practice license issued by the provincial-level finance authority to overseas accounting firms have a specified validity period?

A temporary auditing practice license issued to accounting firms from Hong Kong SAR and Macao SAR is valid for 5 years. A temporary practice license issued to accounting firms from Taiwan is valid for one year, and a license issued to foreign accounting firms is valid for 6 months. If a temporary auditing practice license has expired, a new application should be submitted.

Decision of Shanghai Municipal Finance Bureau 

Name of certificate	Method of decision document service	Deadline of decision document service
Temporary Audit Practice Certificate for Overseas Accounting Firms	Direct courier delivery	10 working days after the decision is made

 

Note: The English version is for reference only; the official Chinese document shall prevail.