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Regulations China Sep 4, 2026

CSRC drafts stricter private fund fundraising rules, comments close Oct 4 2026

On September 4, 2026 China's securities regulator (CSRC) published draft Administrative Measures for Fundraising by Private Investment Funds for public comment through October 4, 2026. It raises qualified-investor bars (RMB 5M household financial assets or RMB 500k average annual income over 3 years, plus a RMB 1M per-fund minimum; RMB 10M and double thresholds for higher-risk funds), bans return guarantees, nominee and third-party fundraising, and mandates look-through of ultimate investors, audio/video recording, cooling-off periods, and 20-year record retention. It follows a June 2026 State Council directive (Document No. 54) after which zero PE/VC managers registered with AMAC that month, the first such freeze in the system's 12-year history.

Why this matters for founders

Founders raising RMB from onshore private funds should expect slower manager registration, a shrinking pool of small VCs, and heavier investor onboarding (source-of-funds look-through, recorded meetings), so budget extra runway and lean toward established, already-registered funds when closing a round.

Source: Sidley Austin LLP

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