On May 12, 2026, China’s National People’s Congress released its 2026 Legislative Work Plan. Then, on June 23–26, the NPC Standing Committee gave first reading to landmark amendments to the Government Procurement Law and the Bidding Law — the first simultaneous revision in the 20-plus years since both laws took effect. Here is what the agenda means for your China business.
Why It Matters
China’s government procurement market is enormous. In 2025, public procurement spending reached approximately 3.8 trillion yuan (US$523 billion), according to Ministry of Finance data. For foreign-invested enterprises operating in China, access to this market has been a persistent pain point — overlapping rules, inconsistent standards, and ambiguity about whether foreign firms enjoy the same rights as domestic competitors.
The NPC’s 2026 agenda directly addresses several of these friction points. Beyond procurement, the work plan includes revisions to the Trademark Law, the Tax Collection and Administration Law, the Bankruptcy Law, and the Anti-Money Laundering Law — each carrying operational implications for foreign businesses. “This is not a tweak year,” Caixin noted in its analysis. “The legislative slate represents the most ambitious regulatory overhaul since the 2020 Foreign Investment Law took effect.”
The Details
Government Procurement and Bidding Law Reform. For more than two decades, China’s Government Procurement Law and Bidding Law have operated in parallel — the Ministry of Finance overseeing procurement, the National Development and Reform Commission (NDRC) overseeing tendering. Overlapping scope created what practitioners call “dual-track compliance” requiring companies to navigate two separate regimes for the same project.
The draft amendments aim to draw a clear boundary between the two laws and unify rules across the full project lifecycle — from approval through payment. A new provision requires procuring entities to justify abnormally low bids, addressing a long-standing complaint that price-only evaluation disadvantages quality-focused foreign suppliers. China Briefing reports that the amendments explicitly reinforce that foreign-invested enterprises “hold the same rights and opportunities as domestic firms in procurement activities.”
Trademark Law Amendment. The 2026 Trademark Law revision targets bad-faith registrations — a persistent problem for foreign brands. Under the proposed changes, the China National Intellectual Property Administration (CNIPA) gains expanded authority to reject applications filed in bad faith and to accelerate enforcement against trademark squatters. For foreign companies entering China, trademark pre-registration remains non-negotiable, but the amendment should reduce the cost and timeline of defending marks against hijackers.
Tax Collection and Administration Law. The revision introduces digital tax administration tools and strengthens taxpayer rights. One notable provision: the statute of limitations for tax audits is being clarified, giving companies more certainty about their historical exposure. For foreign businesses with complex cross-border structures, this clarity reduces a key operational risk.
Financial Regulation. The agenda also advances revisions to the Anti-Money Laundering Law and the Bankruptcy Law. The bankruptcy revision is particularly relevant for foreign creditors — it streamlines cross-border insolvency recognition and gives foreign creditors clearer standing in Chinese bankruptcy proceedings. In 2025, China recorded 4,893 corporate bankruptcy filings, up 23% year-on-year, according to Supreme People’s Court data.
What You Should Do
These legislative changes will roll out on different timelines — some laws receive final votes in 2026, others extend into 2027. But the preparation window is now. Here is your action checklist:
- Audit your procurement exposure. If your business bids on Chinese government contracts, map your current compliance approach against the draft amendments. The unified regime should simplify processes, but the transition period may create confusion.
- Review your trademark portfolio. Run a CNIPA database check on your key marks. The amendment creates a window to challenge bad-faith registrations with stronger legal backing.
- Assess tax audit risk. With the tax administration law revision clarifying audit timelines, now is the moment to review your transfer pricing documentation and historical filings.
- Update your China legal risk register. The simultaneous revision of 5-plus business-facing laws means your compliance posture from 2025 is already becoming outdated.
For companies considering new China market entry, the procurement reform alone changes the calculus. As China’s new sci-tech investment incentives demonstrate, policy evolution in China is accelerating — and the direction is toward clearer, more standardized rules for foreign participants.
One Data Point
The number to remember: 3.8 trillion. That is the value, in yuan, of China’s public procurement market in 2025. If the procurement law amendments achieve their stated goal of leveling the playing field, foreign companies could compete for a significantly larger share of this market than the estimated 8–10% they capture today. For context, a 1 percentage point share gain in China’s procurement market is worth roughly US$5.2 billion — more than the entire public procurement market of most Southeast Asian countries combined.
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Management and Implementation Framework
Work on china’s 2026 legislative agenda: procurement reform and 5 laws foreign businesses must watch should begin with a documented business objective, not a form or provider quotation. The team should identify the China activity, responsible entity, location, expected start date, transaction or employee population and internal risk tolerance. These facts determine which approvals, records and controls are proportionate.
Sequence the implementation
A practical sequence moves from fact confirmation to option selection, document preparation, authority or counterparty review, implementation and post-launch verification. Dependencies should be visible. No team should assume that registration, a signed contract or a successful system submission proves operational readiness; bank, tax, HR, finance and local operating steps often have separate completion evidence.
Control ownership and evidence
Implementation quality is visible in the evidence trail left behind. For china’s 2026 legislative agenda: procurement reform and 5 laws foreign businesses must watch, the accountable group normally includes the investment committee, China finance lead, treasury owner and legal or tax adviser. Responsibility should be divided between preparation, approval and independent checking. The core file should contain capital plan, ownership and funding approvals, valuation support, foreign-exchange evidence, bank records and investment-performance reporting. Evidence should be dated, attributable to a named owner and linked to the decision or filing it supports. Verbal confirmation is not a substitute for a retained authority notice, counterparty response or approved internal record.
The control calendar should reflect the investment design, approval, funding, deployment and periodic capital review. Dependencies and cut-off dates need to be visible to every function that supplies data. Any external provider should receive a written scope, required inputs, response timetable and escalation route. The company remains responsible for reviewing outputs even when execution is outsourced. Known failure modes include misaligned funding route, trapped cash, approval delay, unsupported valuation and weak control over capital deployment; each should have a preventive check and a named reviewer.
Management review and escalation
Progress reporting should distinguish submitted, accepted, activated and independently verified. The status pack should show the decision required, facts confirmed, assumptions still open, monetary or operational exposure, next deadline and responsible owner. Items that depend on local discretion should be labelled clearly. Escalation should occur when an authority rejects a filing, a counterparty requests materially different evidence, a cost or timing threshold is exceeded, or actual operations no longer match the approved setup.
Before go-live, the responsible executive should confirm that legal form, contracts, system configuration, payment authority and record retention are aligned. A short post-implementation review after the first operating cycle should compare planned and actual time, cost and exceptions. That review is where recurring controls are corrected and where lessons become part of the company standard rather than remaining with an individual adviser.
Practical completion checklist
- State the business decision, scope, city, entity and target date.
- Confirm the current official rule and any local implementation requirement.
- Assign preparation, approval and independent review to named owners.
- Retain the documents, calculations and correspondence supporting the decision.
- Test cost, timing and operational assumptions against a downside case.
- Record unresolved issues and the threshold for management escalation.
- Verify the first completed operating cycle and update the control calendar.
Execution Record and Handover
The final record for china’s 2026 legislative agenda: procurement reform and 5 laws foreign businesses must watch should allow another manager to understand what was decided, which evidence was relied on and which obligations remain open. The handover pack should identify the current operating assumption, the approving executive, the external authority or counterparty involved, the effective date and the next mandatory review. It should also explain any local interpretation, exception or temporary workaround so that it is not mistaken for a permanent rule.
For capital, continuity depends on preserving capital plan, ownership and funding approvals, valuation support, foreign-exchange evidence, bank records and investment-performance reporting. Files should use a consistent naming convention and access should follow the company’s authority matrix. Critical dates belong in a controlled calendar rather than an individual’s inbox. Where a provider holds original submissions or account credentials, the contract and exit plan should guarantee prompt return of records in a usable format.
A quarterly control check should sample one completed transaction or employee cycle, reconcile it to the approved process and record exceptions. Material deviations should be assigned to an owner with a due date; repeated deviations should trigger a process redesign rather than another informal reminder. This creates a defensible link between policy, daily execution and management oversight while keeping the control proportionate to the actual China operation.
