DCC Regulatory & Policy Update 06/26
- hans.au
- 7 days ago
- 18 min read
June 2026
Contents
Foreign Investment & Market Access
1.1. China's Foreign Investment Stabilization Action Plan
Trade & Export (Supply Chain, Export Controls)
2.1. Moving to Enforcement: Two MOFCOM Announcements Operationalize the Economic-Security Toolbox
2.1.1. Announcement No. 24 — the Toolbox for Investigating Targets Related to Industrial Supply Chain Security 2.1.2. Announcement No. 26 — the Strategic-Mineral Export-Control Reporting Mechanism
2.2. Beijing Responds to the United States’ 1260H Expansion and Opens a Second Front Against Japan
Competition & Market Regulation
3.1. SAMR's Crackdown on "Involutionary" Competition
4.1. STA Pilots First Comprehensive VAT Filing Redesign Since the VAT Law Took Effect
Foreign Investment & Market Access
1.1. China's Foreign Investment Stabilization Action Plan
On 22 June 2026, the Ministry of Commerce (“MOFCOM”), the National Development and Reform Commission (“NDRC”) and the Ministry of Finance (“MoF”) jointly released the Action Plan for Stabilizing and Optimizing Foreign Investment Utilization (the "Action Plan"). It follows three consecutive years of falling foreign direct investment. The official line of Beijing is to position China as a destination offering stable, predictable returns through a government that is committed and certain about supporting foreign investment amid geopolitical tensions and economic uncertainty. The Action Plan aims at stabilizing and upgrading the foreign investment framework across five government work areas: providing market access, investment facilitation, promotion, services and guarantees, and investment management. Specifically, it is intended to (i) further open the service sector, finance industry and pharmaceuticals (note the absence of manufacturing) and (ii) address long-standing investor concerns such as cross-border data flows, M&A rules, and reinvestment. Noteworthy is Vice Commerce Minister Ling Ji’s statement that external factors mainly affected fluctuation in incremental foreign investment (read: inflow of new foreign investment), while the impact on the existing base of foreign investment in China (533,000 FIEs as of end-2025, FDI value around US$4 trillion) “remains marginal”. In other words, the foreign investment base is stable in China. At DCC we do observe a hold strategy of practically all of our foreign clients in China (not a single one pulled out completely), albeit operating under a much more difficult environment, often with shrinking revenue and profits.
Key Provisions
Direct onshore listing for qualified foreign-controlled companies. Only a handful of foreign-controlled companies are listed onshore today, Foxconn Industrial Internet and Zhejiang Supor among them. The Action Plan signals an intent to widen the pathway, which will likely only be an option for financially very strong and China-savvy industrial or tech companies.
Capital-markets access. The plan opens government-bond futures and fund-advisory services to foreign institutions for the first time. This likely will be tied to minimum capital requirements, effectively blocking out boutique and SME players.
M&A rule revisions. It calls for revisions to the rules governing foreign mergers and acquisitions of domestic firms. There have been a number of revisions regarding M&A over the last years. We believe large paradigm shifts will not be likely.
Equal-treatment pledges. Foreign firms are promised equal treatment in government procurement, standards-setting, and licensing. In non-strategic areas -
Why This Matters
Onshore listing is the provision worth watching. Apart from the handful of companies named above, the pathway has been closed in practice. Opening it would give foreign-invested enterprises RMB capital that stays put, rather than funding that exits at the first downturn. It also serves the Renminbi internationalisation agenda, which is why we expect this piece to move before the others.
Our March issue covered the 2026 Catalogue of Encouraged Service Imports, which defines which service sectors China wants to attract. The Action Plan sets out the access-opening and incentives to draw foreign investment in. Both regulatory items are complementary in determining demand side requirements; one flags priority sectors, the other lowers the barriers and raises the rewards for entering certain sectors.
What to Watch
Listing-eligibility criteria. Watch for China Securities Regulatory Commission (“CSRC”) guidance specifying which additional foreign-controlled companies qualify for onshore listing beyond the current small cohort.
Bond-futures and fund-advisory access rules. People’s Bank of China (“PBOC”)/CSRC implementing rules on qualification and scope for foreign institutional participants have not yet been published.
Revised foreign M&A rules text. Referenced in the plan but not yet released. Its scope decides whether inbound acquisitions of domestic firms get easier or harder.
Procurement outcomes. Whether foreign firms report actual wins in government tenders and standards bodies in the near future. That is the only test of the pledge that counts. In globally highly competitive sectors, or where China wishes to pursue a high level of autonomy, in short in strategically important sectors we at DCC are skeptical.
Trade & Export (Supply Chain, Export Controls)
2.1. Moving to Enforcement: Two MOFCOM Announcements Operationalize the Economic-Security Toolbox
Within a single 48-hour window in late June 2026, MOFCOM issued two measures that, read individually, look like administrative housekeeping. However, read together, mark a turning point in how China enforces its economic and supply chain security regime: on 22 June 2026 MOFCOM released the “Measures for Investigating the Security of Industrial and Supply Chains” (产业链供应链安全调查工作办法), effective on the same day (“Announcement No. 24”), creating a procedure for investigating foreign restrictions on China's supply chains.
On 24 June 2026 MOFCOM released the “Matters Related to Further Improving Handling of Reports and Violations of Export Control of Dual-Use Strategic Mineral Items” (关于进一步完善战略矿产两用物项出口管制违法违规行为举报处理工作有关事项的公告), effective 1 July 2026 (“Announcement No. 26”), creating a public reporting (whistleblower) system for policing strategic-mineral export-control violations. Neither regulation adds any new substantive controls, but rather build more operational detail to enforce controls.
Background
Throughout 2024 and 2025, China assembled the architecture of its economic-security toolkit:
the strategic-mineral export-control regime (restricting the export of the the rare earths gallium, germanium, and antimony,
the April 2025 rare-earth licensing rules, and October 2025's extraterritorial reach), and
the supply-chain-security framework of State Council Decree 834, which DCC covered in the April 2026 issue.
What was missing were the specific implementation mechanisms to investigate, detect, and act. Announcement No. 24 and Announcement No. 26 fill this gap. After two years of codifying the principles, Beijing is now building the toolbox for them.
By no means is the pairing of two announcements coincidental. Announcement No. 24 was issued by MOFCOM's Cooperation Department (合作司) to implement Decree 834; Announcement No. 26 was issued by MOFCOM's Department of Industry Security and Import-Export Control (产业安全与进出口管制局) in accordance with the Export Control Law and the Foreign Trade Law. Different departments and different legal bases, but a common purpose, released two days apart. In the same time window Beijing also kicked off entity-list actions (Announcement No. 23 adding ten US entities on 22 June, and Announcement No. 27 adding twenty Japanese entities on 29 June, discussed below under No. 3), underscoring that this was a coordinated enforcement burst rather than two isolated announcements.
Crucially, the two announcements face in opposite directions. Announcement No. 24 is the outward-facing weapon: it targets foreign governments and foreign entities that restrict China. Announcement No. 26 is the inward-facing safety net: it targets China's own exporters and the service providers that assist them. Together they represent the offence and defence of a concerted supply-chain-security objective.
Key Provisions
2.1.1. Announcement No. 24 — the Toolbox for Investigating Targets Related to Industrial Supply Chain Security
Announcement No. 24 empowers MOFCOM to open an investigation into foreign states, regions, and international organisations that impose discriminatory prohibitions or restrictions on China's supply chains, as well as into foreign entities and individuals that interrupt normal transactions with Chinese parties or take discriminatory measures causing substantial harm — or a substantial threat of harm — to China's supply-chain security. In assessing harm, MOFCOM may weigh the effect on the security and free flow of a broad list of elements: materials, technology, capital, assets, data, information, personnel, enterprises, and projects.
Investigations can be triggered by domestic Chinese legal persons submitting written evidence and reports, and pursued through MOFCOM’s investigative actions such as questioning, document review, questionnaires, sampling, hearings, etc., including on-site work in the relevant foreign country or region, absent objection. On a finding of harm, MOFCOM may act jointly with other departments to prohibit or restrict goods and technology trade or international services trade; levy special fees; and add organisations and individuals involved in the offending measures to counter-sanction lists under the Anti-Foreign Sanctions Law. Against foreign entities and individuals specifically, MOFCOM may additionally bar them from investing in China, prohibit Chinese parties from dealing or cooperating with them, and restrict the entry, work, stay, or residence of related personnel.
The tool also reaches inward. Under Article 19, Chinese-based organisations and individuals that fail to implement the countermeasures MOFCOM adopts can themselves be restricted from government procurement, tendering, and import-export activity, and barred from receiving or providing cross-border data and personal information.
2.1.2. Announcement No. 26 — the Strategic-Mineral Export-Control Reporting Mechanism
Announcement No. 26 grants any organisation or individual the right to report suspected violations of strategic-mineral dual-use export controls, backed by a dedicated online platform, a hotline, cash rewards for verified named reports, and confidentiality protections. The thirteen categories of reportable conduct effectively is a list of the evasion methods MOFCOM is now hunting. Beyond unlicensed or prohibited exports, they capture physically modifying or splitting items to dodge licensing; routing through a third country to evade controls; the illegal intangible transfer of controlled mineral technology through licensing, investment, joint R&D, employment, teaching, or consulting; and the knowing providing of agency, freight, delivery, customs-clearance, e-commerce platform, or financial services by a third party to the violator.
Two features sharpen the reporting mechanism. First, an affirmative "should have known" duty: an exporter that knows or should know that even non-listed strategic-mineral goods, technology, or services may carry the risks set out in Article 12 of the Export Control Law, but fails to apply for a license, is reportable. Second, a conflict of legal duties trap: it is reportable to accept — or promise to accept — a foreign government's request for access or on-site verification without Chinese authorization. Offsetting these, the measure rewards voluntary self-disclosure: exporters that proactively report their own violations receive lighter or reduced penalties.
Why This Matters
On its face, each announcement is procedural — a complaints hotline and an investigation manual. Such framing would be grossly misleading. Their shared significance is the pivot from rule-making to enforcement, and the way both significantly intend to mobilize private parties as instruments of the state: Announcement No. 24 lets domestic firms trigger retaliation investigations, and Announcement No. 26 lets anyone report an exporter for reward. China has long studied how its economic-security rules are evaded and circumvented, and is now systematically applying the intelligence to enforce them.
For foreign business, the two announcements create exposure from opposite directions at once. A company whose home government tightens restrictions on China may find itself, its executives, or its China dealings the subject of an Announcement No. 24 investigation and countermeasure — and Article 19 means its Chinese partners and subsidiaries face penalties for failing to help enforce that countermeasure, deepening the pressure to choose a side. Simultaneously, under Announcement No. 26, the same company can be reported as an exporter or, more subtly, as a facilitator: the service-provider category pulls banks, freight forwarders, customs brokers, and platforms into the liability net for merely servicing a violator. And its cooperation with a US or EU end-use check can itself become a reportable breach of Chinese law.
Between a rock and a hard stone: businesses being required to participate in China's countermeasures while in the same time being penalised for complying with foreign controls is the defining compliance problem these announcements crystallise. The abovementioned mechanism does not sit in isolation: it layers directly onto China's blocking rules and the first-ever MOFCOM blocking order of 2 May 2026, and, read alongside the Outbound Investment Regulation (Decree 837) on the investment side, completes a clear policy thread for 2026. China is closing the gaps between its trade, investment, and export-control regimes, and, this quarter, giving each an enforcement mechanism. The strategic-mineral controls that function as leverage in the critical-minerals contest with the US and EU can only be as strong as their enforcement is. Announcement No. 26 supplies that enforcement, while Announcement No. 24 arms Beijing to investigate and answer the foreign restrictions that leverage is meant to deter.
What to Watch
The first supply-chain security investigation opened under Announcement No. 24 against a named foreign measure — most plausibly an EU or US restriction — will show how quickly framework becomes action, and how the investigation and consultation process works in practice as against how it reads on paper. The first enforcement action or reward payout under Announcement No. 26 will signal how aggressively the reporting system is used, and whether facilitators as well as exporters are pursued.
Two narrower developments deserve particular attention. The first invocation of Article 19 against a Chinese-based subsidiary of a multinational would be the clearest test of the "help us retaliate" duty imposed on foreign-owned China entities and the sharpest illustration of the conflict of legal duties bind. And any implementing guidance clarifying Announcement No. 26's "should have known" standard will matter greatly, because that affirmative due-diligence obligation — extending beyond the published control lists — is currently the vaguest and most consequential requirement across both texts.
2.2. Beijing Responds to the United States’ 1260H Expansion and Opens a Second Front Against Japan
In the May 2026 issue we reported MOFCOM's first-ever Blocking Order, issued on 2 May 2026 against the U.S. Treasury Office of Foreign Assets Control (“OFAC”) designation of five Chinese "teapot" refineries. June brought the next round. It came faster, reached further, and for the first time pointed at Japan as much as at the United States.
The trigger was on the U.S. side. On 8 June 2026, the U.S. Department of War (“DoW”) published a revised Section 1260H List of Chinese military companies. It added 65 entities (17 parent companies and 48 subsidiaries), removed 10, and now runs to 188 names. The additions go well beyond the defence sector, including the likes of Alibaba, Baidu, BYD, NIO, battery makers CALB and EVE Energy, solar manufacturers JA Solar and Trina Solar, WuXi AppTec, and the robotics firm Unitree. The Department cited indirect ownership by the State-owned Assets Supervision and Administration Commission (“SASAC”) and military-civil fusion work with the Ministry of Industry and Information Technology (“MIIT”). MOFCOM called the designations an abuse of state power.
Beijing responded on 22 June 2026 with two measures issued within minutes of each other, added implementing rules for its supply-chain regime the same day, and then extended to Japan on 29 June 2026.
Key Provisions
The U.S. trigger — the expanded 1260H List expanded (8 June 2026). Three National Defense Authorization Act (“NDAA”) provisions attach to the list. Section 805 of the FY24 NDAA bars the DoW from contracting directly with listed firms commencing 30 June 2026. Section 851 of the FY25 NDAA extends that bar to companies that contract with anyone lobbying on behalf of a listed firm. Section 1532 of the FY26 NDAA, in force since 17 January 2026, bars DoW contractors from using AI products from listed entities in the course of contract performance. Indirect procurement restrictions are scheduled to follow in June 2027.
China's answer — MOFCOM Export Control List (22 June 2026). MOFCOM added ten U.S. entities to the Export Control List (MOFCOM Announcement No. 23). Chinese exporters may not supply them with dual-use items, and organisations or individuals anywhere are barred from transferring China-origin dual-use items to them. Ongoing activity has to cease immediately. The list includes the companies MP Materials and USA Rare Earth, Washington's two designated champions for breaking China's grip on rare earth magnets, alongside aerial and marine drone makers and their component suppliers.
China’s Ministry of Finance — government procurement ban (22 June 2026). The Ministry of Finance barred forty-six U.S. companies from Chinese government procurement, effective on issuance: Lockheed Martin, Raytheon Missiles & Defense, Boeing Defense Space & Security, General Dynamics, BAE Systems, Teledyne, Anduril and Shield AI among them. U.S.-invested enterprises operating in China are expressly carved out.
MOFCOM — Supply-chain Investigation Measures (22 June 2026). Issued in the same window, MOFCOM Announcement No. 24 supplied the implementing procedure for Decree 834 (see Update April 2026). Its full mechanics are covered in this issue's companion piece (see above No. 2). For purposes here, three points matter: according to Article 3 of the Announcement No. 24 MOFCOM may open an investigation where a foreign party disrupts normal commercial transactions with Chinese counterparties, applies discriminatory measures, or threatens harm to Chinese supply-chain security. Article 5 allows Chinese companies to petition for an investigation with supporting evidence. Article 18 sets out the consequences: restrictions on trade, investment, transactions with Chinese parties, and on entry, work and residence in China, extendable to entities the foreign party controls or helped establish.
The second front — Japan (29 June 2026). MOFCOM added 20 Japanese entities to the Export Control List and a further 20 to the Watch List (MOFCOM Announcement No. 27). This is the latest round of a campaign running since January 2026, when Beijing banned dual-use exports, including rare earths and permanent magnets, to Japanese military end-users following certain remarks of Prime Minister Takaichi regarding Taiwan. The February round caught subsidiaries of Mitsubishi Heavy Industries, Kawasaki Heavy Industries, IHI and Fujitsu, plus Subaru and TDK. The June round targets four defence research institutes, including the National Institute for Defense Studies, units of Mitsubishi Electric and Mitsubishi Heavy Industries, and drone makers ACSL and Terra Drone. The Watch List is the operationally sharper instrument: exporters shipping dual-use items to a watch-listed entity lose access to general licences and to registration- and filing-based authorisation. Each shipment then requires an individual licence, a risk assessment report on the listed entity, and a written undertaking that the goods will not contribute to Japan's military capability. The statutory review period in Article 17(1) of the Dual-Use Export Control Regulations does not apply, so there is no deadline by which MOFCOM must decide.
Why This Matters
The headline lists are the least important part. Most of the 46 procurement-banned firms sell nothing to Chinese government buyers and were already under Chinese sanctions; MP Materials does not depend on Chinese inputs. The signals from the mentioned listings are real but the direct commercial damage seems small. What matters, as in the companion piece (see above No.2), are the operational tools built around the lists. And the month of June shows that the sanction tools aimed at concrete targets.
Announcement No. 24 has the widest reach. Until June, Decree 834 was a framework without a procedure. It now has one, including a route for Chinese companies to petition for an investigation. A European or Japanese supplier that exits a Chinese customer for sanctions, export-control or ESG reasons can now become the subject of a formal MOFCOM investigation initiated by that very customer, and the exposure runs to named individuals through entry, work and residence restrictions, so the exposure is on the personal as well as on the corporate level. This is the operational follow-through we flagged when Decree 834 was issued.
For companies in the Japanese supply chain, the Watch List is the immediate practical problem. Losing general-licence eligibility converts routine shipments into per-shipment applications with a documentary burden and no decision deadline. That is a production-planning issue before it is a compliance issue, and it applies to any China-based operation supplying a listed Japanese group, including the Chinese subsidiaries of European companies.
On the U.S. side, the exposure has moved past defence contractors. With Alibaba and Baidu now listed, Section 1532 means any DoW contractor running Chinese AI models needs to audit its systems. Section 851 reaches law firms, lobbying shops and consultancies with any lobbying relationship to a listed company, and by extension their other DoW-contracting clients.
One thread from our May issue can now be closed. OFAC's General License V, which authorised the wind-down of Hengli Petrochemical transactions, ran only to 24 May 2026 and no extension has been published. The Iran-related General License U had already lapsed on 19 April 2026 without renewal. The conflict of legal duties exposure we flagged is therefore no longer hypothetical: the expiry of both general licences removes the wind-down cover, leaving affected parties simultaneously exposed to a live U.S. designation and a live Chinese Blocking Order.
What to Watch
The first investigation under Announcement No. 24. Whether MOFCOM opens one on its own initiative or on a Chinese company's petition will show if Decree 834 is a deterrent or an active enforcement tool.
A Chinese counter-measure to the commercial-tech designations? Beijing has so far retaliated only against U.S. defence names. Alibaba, Baidu and BYD were added on 8 June 2026; watch whether a countermeasure follows for the commercial side.
Further escalation against Japan? Watch in particular how rare-earth export licences are handled for Japanese-owned manufacturing inside China, which is where the leverage actually bites.
First enforcement under the 2 May Blocking Order? No penalty or Article 12 civil claim has yet tested it. The first case will show how aggressively Beijing intends to enforce.
Possible U.S. NS-CMIC designations. Section 8531 of the FY26 NDAA requires a report to Congress on whether 1260H-listed firms qualify for Treasury’s Non-SDN Chinese Military-Industrial Complex Companies (“NS-CMIC”) list, which would bar U.S. persons from dealing in their securities. That would be consequential for the U.S.-traded additions, notably Alibaba, Baidu and NIO.
Competition & Market Regulation
3.1. SAMR's Crackdown on "Involutionary" Competition
Chinese regulators now use the term "involutionary" or "cutthroat" competition (内卷式竞争) routinely. It describes margin-eroding price rivalry in sectors with chronic overcapacity: EVs, solar and e-commerce. Policymakers treat it as a drag on innovation and on long-term industrial health, not as ordinary market behaviour.
On 5 June 2026, the State Administration for Market Regulation (“SAMR”) released its Annual Report on Antitrust Enforcement in China for 2025. It records 20 monopoly cases opened and 22 closed, fines of roughly ¥653 million (about US$96.4 million), and 706 merger reviews, up 9.8% year-on-year. It also records nearly 60,000 government policy measures screened for fair-competition compliance. Separately, SAMR's 2026 unfair-competition campaign handled 11,465 cases in the first half of the year, 2,005 of them involving false online advertising or online commercial defamation.
Key Provisions
SAMR has signaled plans to develop new rules for identifying improper pricing practices, specifically predatory low-price dumping.
The regulator intends to strengthen price-regulation and enforcement tools and refine the legal-liability framework tied to unfair competition.
Nearly 60,000 government policy measures were screened for fair-competition compliance in the reporting period, at every level of government. The review covers local industrial-policy and incentive schemes, not only company conduct.
Why This Matters
"Involutionary competition" is not ordinary antitrust language. Framing price wars as a macroeconomic problem tells you the coming predatory-pricing rules will be aimed at named overcapacity sectors, EVs and solar above all, rather than drafted as neutral guidance.
For multinationals, the number that matters is 60,000. Those are policy measures, not companies. The target is the local incentive packages, tax rebates and land terms that officials negotiate to attract investment. The March issue covered the anti-tax-attraction campaign; this is the same scrutiny arriving through a competition-law door.
Any investment agreement resting on informally negotiated local benefits should be reviewed on that basis. The exposure is not a fine. It is that the benefit is withdrawn and the business case behind the investment stops working.
Platform and e-commerce companies now sit on three tracks at once: merger control, unfair-competition enforcement, and this policy screening.
What to Watch
Draft predatory-pricing rules. The promised rules on improper and predatory low-price dumping have not appeared. Whether a public comment period follows will indicate how settled the drafting is.
First enforcement case under the refined liability framework. Once published, it will show how aggressively the new pricing standards are applied.
Whether EV and solar pricing become explicit enforcement targets as the "involutionary competition" campaign matures.
Continued overlap with the local tax-incentive crackdown flagged in the March issue. Coordinated SAMR and STA action against the same incentive schemes, from both a competition and a tax angle, is the thing to look for.
Tax
4.1. STA Pilots First Comprehensive VAT Filing Redesign Since the VAT Law Took Effect
China's Value-Added Tax (“VAT”) Law took effect 1 January 2026. In June 2026, the State Taxation Administration (“STA”) launched a pilot of a redesigned VAT and surcharge return - the Trial VAT and Surcharges Return (增值税及附加税费申报表（试行）) - in five provinces and municipalities. This is the first full redesign of the filing system since the Law came into force, and is intended as the national template once the pilot closes. The STA is running it in phased steps described as "dual-track verification, single-track operation, full rollout" (双轨验证、单轨运行、全面推广). Non-pilot taxpayers continue to file on the existing forms under STA Announcement 2026 No. 6 (国家税务总局公告2026年第6号) and do not use the new return.
Key Provisions
New Business Information Schedule (业务信息表). The redesigned return introduces a schedule collecting each taxpayer's business type, applicable tax preferences, and special transaction types.
Auto-generated, profile-based filing interface. Rather than a single uniform form, the system uses the taxpayer's declared profile to generate a customized filing interface, hiding line items that do not apply so that irrelevant fields are suppressed.
Continuity of underlying logic. The main return and principal appended schedules keep essentially the same framework and workflow; the adjustment required is confined to the new line items and the customised-filing method.
Restructured coding. The trial return rebuilds the line-item coding system and introduces business-profile tags (业务画像标签), part of a shift the STA frames as moving from invoice-based control ("以票控税") toward transaction management (交易管理) and full-lifecycle data governance.
Related developments the same month: the STA also released the 2026 Version B export VAT refund rate library (出口退税率文库B, 5 June 2026), reflecting revised Harmonized System (“HS”) customs codes, and Shanghai opened a Carbon Border Adjustment Mechanism (“CBAM”) advisory window (12 June 2026) on its International Trade Single Window for exporters of steel, aluminum, cement, and fertilizer affected by the EU's carbon border mechanism.
Why This Matters
Taxpayers now declare their business type, claimed preferences and transaction types up front, and the system builds the filing interface from that declaration. The STA can then compare what a company says it is against what it actually files. Audit selection shifts from reviewing forms after the fact to flagging mismatches as they arise.
The pattern will be familiar from the March 2026 issue's coverage of the anti-tax-attraction campaign. Eligibility checks are being built into the system rather than left to later audits. The deeper intention is the move away from invoice-based control (以票控税) toward transaction-level data governance — the return is being turned into a live reconciliation tool, not just a payment form.
Companies claiming more than one preference are the ones affected. Straddling a regional incentive zone and an industry-support programme, for example, is a profile the old uniform form did not surface and the new one does. Where claimed preferences and actual operations have drifted apart, the pilot provinces are where that shows up first.
What to Watch
Pilot expansion timeline. Whether the five-province pilot goes national on schedule, or slips.
Treatment of multi-jurisdictional or hybrid preference claims in the Business Information Schedule (业务信息表). This is where practical friction for multinationals, straddling a regional incentive zone and an industry-support programme, is most likely.
The still-undefined "prescribed time limit" for export VAT refund filings under the VAT Law Implementation Rules (增值税法实施条例). It interacts with the new Version B refund rate library and with the Zhejiang guidance on export VAT invoices. National guidance fixing the deadline is outstanding.
Whether the Zhejiang export-invoice guidance becomes the national template, running in parallel with this filing-system pilot.
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