On 22 October 2026, the National Development and Reform Commission (NDRC) promulgated the Measures for the Administration of Outbound Investment (hereinafter referred to as “Decree No. 49” or the “New Measures”), which shall come into force on 1 December 2026.

​On October 23, 2026, the China Securities Regulatory Commission (CSRC) released the Measures for the Administration of Private Investment FOFs (Draft for Comments) (hereinafter referred to as the “Draft”), soliciting public comments on matters including FOF identification, diversified investment, investment tiers, qualification requirements for managers and operational administration. Comments shall be submitted by November 23, 2026.

By presenting typical dispute scenarios, enterprises are prompted to conduct an overall diagnosis of evidence, responsibilities and goals before taking action.

By clarifying the law, explaining the reasoning, sorting out the evidence and soothing the emotions, we aim to create favorable space for the subsequent defense.

Clarify the rules for determining responsibilities in different scenarios, taking into account both rights protection and technological innovation.

Focus on ongoing financing and value segmentation, and provide practical paths for resuming construction of abandoned projects.