Information date: 24 October 2026 — Under China's Company Law and accounting rules, foreign-invested companies, joint-stock companies and most companies limited by shares must have annual financial statements audited by a certified public accounting firm licensed in mainland China; the audit report normally accompanies the annual corporate income tax filing, which is due within five months of year-end — 31 May for a 31 December year-end — while the National Enterprise Credit Information Publicity System annual report must be filed by 30 June. Knowing that statement is not enough for an operating, research or compliance decision. The team must first establish who and what it applies to, how the effect reaches the real process, and which evidence would justify action.
Verified facts and scope
Under China's Company Law and accounting rules, foreign-invested companies, joint-stock companies and most companies limited by shares must have annual financial statements audited by a certified public accounting firm licensed in mainland China; the audit report normally accompanies the annual corporate income tax filing, which is due within five months of year-end — 31 May for a 31 December year-end — while the National Enterprise Credit Information Publicity System annual report must be filed by 30 June.
Applies to wholly foreign-owned enterprises, Sino-foreign equity and cooperative joint ventures, and branches of foreign companies with independent accounting; before scoping, confirm the legal form, whether a statutory audit exemption applies (for example small limited liability companies with no external shareholders or certain holding-only entities), the accounting standard used (CAS or IFRS as adopted), the fiscal year-end, and whether local tax or statistical bureaus impose extra attachments.
How the effect reaches operations
The audit obligation flows from the annual inspection-substitute mechanism built into the credit information publicity system: the tax bureau, SAMR and the shareholder of record all rely on an independently certified set of accounts, so a CPA firm's report becomes the shared reference point; the five-month tax deadline drives fieldwork, which is why auditors request bank confirmations, inventory counts and contract samples in January and February rather than in April.
The most common misjudgement is assuming that a company with no revenue or dormant status needs no audit — dormant entities still owe the annual report and often the audit; a second risk is engaging a Hong Kong or overseas firm whose report is not accepted by the tax bureau; a third is filing the tax return before the audit is complete, which locks in numbers that later require an amended filing and can trigger a comparative reconciliation request.
For “FAQ: China's Year-End Statutory Audit for Foreign-Invested Companies — Which Entities Must Appoint a CPA Firm, What the Report Covers and the Filing Deadlines”, official rules or published findings, direct evidence from the relevant product or process, and assumptions that remain untested should be recorded separately. A broad source defines the external boundary; it does not replace batch records, protocols, contracts, labels or direct observations.
Decision
If the year-end is 31 December, engage the firm by mid-February: choose a firm that is registered with the local finance bureau and has experience with the entity's accounting standard and industry; if the entity is genuinely exempt under the small-company criteria, obtain a written confirmation from the local tax office rather than relying on general guidance; if the group consolidates under IFRS, decide early whether a single audit serves both purposes.
Implementation checklist
- Confirm in writing whether the entity is exempt from the statutory audit before the books close.
- Send bank confirmation and legal-representative signature authorisations to the auditor in January.
- Diarise 31 May for the tax filing and 30 June for the credit-information annual report.
- Assign one decision owner, one implementation owner and a dated review point for “FAQ: China's Year-End Statutory Audit for Foreign-Invested Companies — Which Entities Must Appoint a CPA Firm, What the Report Covers and the Filing Deadlines”.
- For “FAQ: China's Year-End Statutory Audit for Foreign-Invested Companies — Which Entities Must Appoint a CPA Firm, What the Report Covers and the Filing Deadlines”, archive the source page, access date, applicable population or entity, and internal evidence both supporting and opposing the current decision.
- When a rule, formulation, supplier, protocol or observed result changes, reopen only the affected question in “FAQ: China's Year-End Statutory Audit for Foreign-Invested Companies — Which Entities Must Appoint a CPA Firm, What the Report Covers and the Filing Deadlines”.
Evidence and review
For “FAQ: China's Year-End Statutory Audit for Foreign-Invested Companies — Which Entities Must Appoint a CPA Firm, What the Report Covers and the Filing Deadlines”, start with one real case rather than an abstract checklist. Record the input version, responsible owner, start time, observed result and stop condition. If the team cannot complete “Confirm in writing whether the entity is exempt from the statutory audit before the books close.” with current evidence, it should not expand the process to more products, patients, suppliers or markets. The first review should focus only on facts capable of changing the decision.
The second control follows “Send bank confirmation and legal-representative signature authorisations to the auditor in January.”. Keep the source date, applicable population or entity, deadline, cost effect and owner in the same evidence file. A wording preference does not justify a new version. A repeated discrepancy, an unsupported health claim or a regulatory mismatch does: correct that point and hold release until the evidence is available.
After “Diarise 31 May for the tax filing and 30 June for the credit-information annual report.”, compare the intended outcome with what actually happened. Apply the same success criteria to each later expansion. If only one number, date or responsibility changes, update that field and the affected conclusion instead of recreating evidence that remains valid. This keeps the decision traceable without turning review into an open-ended rewrite cycle.
Limits of the conclusion
This is general information on the audit obligation, not accounting, tax or legal advice; whether a specific entity must be audited depends on its legal form, size thresholds and local practice, and should be confirmed with a licensed firm and the competent authority.
