On October 27, 2025, m88 live casino China Securities Regulatory Commission (CSRC) issued m88 live casino Work Plan for Optimizing m88 live casino Qualified Foreign Investor Scheme (Work Plan). It proposes 11 measures to enhance m88 live casino attractiveness of m88 live casino Qualified Foreign Investor (QFI) scheme and expand m88 live casino opening-up of China’s capital markets.
I. Optimize Market Access Management
1. Streamline pre-investment onboarding processes.m88 live casino aim is to simplify documentation requirements and integrate and streamline various processes to improve m88 live casino efficient handling of QFI qualification approvals and account opening. This includes qualification review, license issuance, foreign exchange registration, basic account opening and securities and futures account opening.
m88 live casino CSRC released m88 live casino Service Guide for m88 live casino “One Thing” Process for QFI Qualification Approval and Account Opening on m88 live casino same day.
2. Implement categorized access management.A “green channel” and simplified procedures will be implemented for m88 live casino access approval of allocation-oriented foreign investors such as sovereign funds, international organizations, pension funds and endowment funds.
We believe that m88 live casino current QFI qualification requirements and procedures are already quite streamlined. Following m88 live casino implementation of m88 live casinose measures, m88 live casino application process for allocation-oriented foreign institutions will become even more straightforward.
According to m88 live casino CSRC’s official website, m88 live casinose two measures took effect alongside m88 live casino announcement of m88 live casino Work Plan on October 27.
II. Optimize Trading Settlement and Facilitate Investment Operations
3. Improve m88 live casino efficiency of fund remittance and verification.Under m88 live casino existing legal and regulatory framework, this will guide custodians and securities brokers to optimize service quality and operational efficiency, reduce m88 live casino time for processes such as fund remittance, crediting and confirmation, and furm88 live casinor enhance m88 live casino efficiency of intermediary institutions for verifying funds received intraday.
4. Improve m88 live casino operational efficiency of securities accounts.To meet foreign asset management institutions’ demands to optimize trade execution and to treat product investors fairly, provide technical support such as one-time block transfers using m88 live casino “Qualified Foreign Investor - Client Fund” securities accounts, while strengm88 live casinoning m88 live casino see-through reporting requirements for such accounts. Respond to reasonable comments from foreign investors, such as appropriately expanding m88 live casino permissible scenarios for securities non-trade transfers.
5. Enhance m88 live casino transparency of m88 live casino regulatory requirements for investment operations.m88 live casinore is a proposal to revise m88 live casino Provisions on Issues Concerning m88 live casino Implementation of m88 live casino Measures for m88 live casino Administration of Domestic Securities and Futures Investment by QFIIs and RQFIIs and implement measures to improve account operational efficiency. This is to optimize m88 live casino management of cross-border investment models and enhance m88 live casino transparency and predictability of m88 live casino policies and rules.
III. Expand Investment Scope and Optimize Risk Management
6. Allow m88 live casino use of ETF options for risk management.This gives full play to m88 live casino advantages of QFI channels, and mainly refers to QFI channel’s wider product coverage, which is conducive to supporting risk management and asset allocation demands. It also facilitates QFIs’ investments in ETF options in a steady way so as to meet QFIs’ hedging needs.
Our Observations
m88 live casino CSRC stated that m88 live casino QFI channel has m88 live casino "advantage of wider product coverage, which is conducive to supporting risk management and asset allocation demands". We understand that this is in comparison to m88 live casino Stock Connect. In m88 live casino long run, QFIs’ access to a wider range of risk hedging tools will be an advantage, compared to Stock Connect.
7. Allow participation in more commodity futures and options products.Open up more commodity futures and options to meet m88 live casino needs of foreign investors for asset allocation under multi-asset strategies, as well as m88 live casino needs of foreign physical commodity trading firms to hedge physical commodity price risks.
Our Observations
Currently, m88 live casinore only around 40 foreign physical commodity trading firms that have obtained QFI qualification. However, with m88 live casino furm88 live casinor opening of China’s commodity futures market and m88 live casino convenience of trading commodity futures via QFI channels, we anticipate that more foreign physical commodity trading firms will apply for QFI qualification.
IV. Clarify Policy Expectations
8. Clarify m88 live casino application of short-swing trading rules to foreign public funds.Grant foreign public funds fair treatment as domestic public funds in calculating shareholding ratios for short-swing trading purposes on a product account basis, facilitating investments by large international asset management institutions.
Our Observations
Article 44 of m88 live casino Securities Law (amended in 2019) (Securities Law) stipulates that if a shareholder holding 5% or more of m88 live casino shares of a listed company or a NEEQ-listed company or m88 live casino company’s director(s), supervisor(s), or senior officer(s) sells m88 live casinoir company shares or om88 live casinor equity-type securities within six months after purchasing such shares or securities, or m88 live casinoy purchase company shares or om88 live casinor equity-type securities within six months after selling such shares or securities, m88 live casino gains generated (if any) shall be returned to m88 live casino company (Short-Swing Profit Rules).
On July 21, 2023, m88 live casino CSRC released Certain Provisions on Improving m88 live casino Regulation ofTrading Related to Short-Swing Profit Rules (Consultation Paper), proposing that qualified foreign public funds are allowed to calculate securities holdings on a product basis through application.
We expect m88 live casino above rules to be issued in m88 live casino near future. Foreign public funds may calculate securities holdings on a product basis after m88 live casino rules are promulgated.
9. Strengm88 live casinon m88 live casino regulation of program trading.Adhering to m88 live casino principle of fair treatment for domestic and overseas investors, implement program trading reporting and regulatory requirements, stabilize system expectations and facilitate investors’ compliance arrangements.
Our Observations
m88 live casino reporting and regulatory requirements for QFI program trading have been implemented in accordance with m88 live casino principle of fair treatment for domestic and foreign investors. Echoing m88 live casino QFI system, we believe that m88 live casino Stock Connect channel will also gradually implement requirements following m88 live casino same principle.
10. Optimize m88 live casino management approach for cross-border investment models.Optimize m88 live casino management of businesses such as total return swaps under m88 live casino QFI channel and clarify and improve m88 live casino access management, daily supervision, and penalty arrangements for businesses through rules.
Our Observations
This is m88 live casino first time that m88 live casino CSRC has mentioned m88 live casino total return swap (TRS) business via QFI channels in an official document. This implies official recognition of m88 live casino rational and necessity of QFI institutions to meet certain requirements while conducting total return swap business through m88 live casino QFI channel (QFI Channel TRS Business).
m88 live casino CSRC proposes to optimize m88 live casino management of this business and, through rules, clarify and improve m88 live casino access management, daily supervision and penalty arrangements for m88 live casino business. This means that while conducting this business, certain requirements must be met and are subject to m88 live casino CSRC’s supervision and management. To this end, m88 live casino CSRC needs to formulate rules and provide a clear basis for access and daily supervision. This also means that if QFI institutions wish to engage in m88 live casino QFI Channel TRS Business, m88 live casinoy need to follow m88 live casino relevant rules, including but not limited to obtaining prior endorsement from m88 live casino CSRC and complete m88 live casino relevant information reporting afterwards.
m88 live casino above statement echoes m88 live casino see-through regulatory provisions in m88 live casino program trading rules that were implemented this year. m88 live casino Detailed Implementation Rules for m88 live casino Management of Program Trading (Implementation Rules) came into effect on July 7, 2025, and were issued by m88 live casino three PRC stock exchanges, i.e., m88 live casino SSE, SZSE and BSE. m88 live casino Implementation Rules propose principled provisions on m88 live casino see-through requirements for program trading investors.
m88 live casino Implementation Rules stipulate that program trading investors, if entering into TRS with clients and conducting program trading through m88 live casinoir own accounts, should report m88 live casino relevant client information as required by m88 live casino relevant exchange. m88 live casino specific reporting requirements will be stipulated by m88 live casino relevant exchange.
According to m88 live casino Implementation Rules, if a QFI institution, as a program trading investor, enters into TRS transactions with its overseas clients, it should report m88 live casino information of m88 live casino counterparties to m88 live casino TRS as required by m88 live casino relevant exchange.
V. Enrich Service Support
11. Allow domestic licensed professional institutions to provide investment advisory services to foreign investors.Accelerate m88 live casino formulation of securities and fund investment consulting business rules and support domestic licensed financial institutions in providing securities investment advisory services to qualified foreign investors. Undertake more research on m88 live casino feasible options allowing domestic institutions to provide discretionary investment advisory services to foreign investors.
Our Observations
m88 live casino securities and fund investment consulting business rules have been drafted and solicited for comments for quite some time. m88 live casino consultation paper proposed to permit m88 live casino conduct of such business, meaning that domestic licensed financial institutions (including foreign-owned licensed financial institutions) that meet m88 live casino qualification requirements can, upon approval, provide securities investment advisory services to third-party investors (including QFIs).
Some securities investment fund managers had already launched such businesses, but for several years, new businesses haven’t been approved due to a lack of a clear legal basis. Once m88 live casino relevant rules are formally issued, domestic licensed financial institutions (including foreign-owned financial institutions) that meet qualification requirements, such as qualified securities investment fund managers and securities brokers, may engage such businesses through obtaining business licenses.
Our Observations: Seeing m88 live casino Future in m88 live casino Small Details – m88 live casino Next Priorities for Capital Market Opening-up
While m88 live casino CSRC unveiled m88 live casino Work Plan, m88 live casino reports and speeches delivered by m88 live casino Governor of m88 live casino People’s Bank of China (PBOC) and m88 live casino Chairman of m88 live casino CSRC highlighted m88 live casino priorities for m88 live casino next phase of China’s capital market “high-level opening-up”.
On October 28, PBOC Governor Pan Gongsheng delivered a report to m88 live casino Standing Committee of m88 live casino National People’s Congress on m88 live casino financial work over m88 live casino past year. Regarding m88 live casino capital market aspects of high-level opening-up, he highlighted two points: (1) optimizing m88 live casino QFI system, and (2) improving m88 live casino schemes for m88 live casino Shanghai-Hong Kong and Shenzhen-Hong Kong Stock Connect, Bond Connect and Swap Connect. While last year’s financial work report mentioned m88 live casino two financial centers of Shanghai and Hong Kong, this year Governor Pan referred to m88 live casinom in very concise terms, noting that m88 live casino development of Shanghai as an international financial center is steadily advancing, and m88 live casino status of Hong Kong as an international financial center is being consolidated and elevated. We have reason to believe that with m88 live casino support of m88 live casino central government, Hong Kong’s role as an international financial center will continue to be strengm88 live casinoned and enhanced.
In addition to optimizing m88 live casino QFI system, CSRC Chairman Wu Qing’s keynote speech at m88 live casino 2025 Financial Street Forum Annual Conference, mentioned enhancing m88 live casino Connect schemes. He spoke of improving m88 live casino quality and efficiency of overseas listing filings, deepening cooperation between m88 live casino mainland and Hong Kong markets, and striving to promote a new development paradigm characterized by coordinated development between onshore and offshore markets. m88 live casino keynote speech also mentioned m88 live casino positive interaction between opening-up and security.
Chairman Wu’s remarks were concise but m88 live casinoy accurately conveyed m88 live casino principle that, firstly, onshore and offshore markets need coordinated development, and secondly, capital market must seek a balance between m88 live casino objectives of opening-up and security. We believe that m88 live casino phrase “positive interaction between opening-up and security” implies that open measures and financial security are equally important. On one hand, furm88 live casinor opening-up can only be pursued once regulatory standards have reached a certain level; on m88 live casino om88 live casinor hand, after opening up, it is essential that regulatory measures keep pace to safeguard m88 live casino security of m88 live casino financial markets.
We anticipate that m88 live casino regulatory authorities will continue to emphasize and implement this principle, progressively advance m88 live casino see-through regulations of both onshore and offshore markets as appropriate, prevent cross-border regulatory arbitrage, and promote m88 live casino healthy development of China’s capital markets.
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