On February 17, 2023, the China Securities Regulatory Commission (CSRC) announced rules related to the registration-based stock issuance system, marking a full transition to the "registration-based" era, 33 years after the establishment of China's capital markets. In four years since President Xi's November 2018 announcement of the registration-based pilot reform of the Shanghai Stock Exchange's (SSE) STAR Market, more directly impactful on market participants than the construction and practice of the offering and trading system may be regulatory actions and dispute resolution. In these intervening years, we have witnessed a comprehensive revision of the Supreme People's Court's Judicial Interpretation of False Statements issued nearly 20 years ago, the integration of the bond markets with cross-market administrative enforcement and unified legal applicability, the establishment of a Chinese-style securities class action mechanism and the first "representative litigation", a decrease in the "shell" value of listed companies and the corresponding transfer of civil liability from issuers to intermediaries, and regulatory storms waged by the CSRC and the downfall of certain high-profile enterprises.

On February 1, 2023, the China Securities Regulatory Commission ("CSRC") solicited public opinions on the Measures for Administration of the Registration-based Initial Public Offerings of Stocks (Draft for Comment) (《首次公开发行股票注册管理办法（征求意见稿）》). Shanghai Stock Exchange, Shenzhen Stock Exchange, Beijing Stock Exchange, National Equities Exchange and Quotations, China Securities Depository and Clearing Corporation Limited ("CSDC"), and China Securities Finance Corporation Limited ("CSF") also solicited public opinions on supporting business rules for the full implementation of the registration-based initial public offering ("IPO") system. Based on this, Han Kun Law Offices have published a series of articles on the topic of the full implementation of the registration-based IPO system, providing detailed interpretations of key changes of the new IPO rules, refinancing policies for listed companies, and restructuring rules for listed companies.

On December 30, 2022, the Asset Management Association of China ("AMAC") issued a consultation draft of the Measures for Registration and Filing of Private Investment Funds (《私募投资基金登记备案办法 (征求意见稿)》) and the ancillary Guidelines No. 1-3 on private fund manager registration (collectively, the "Draft Rules"). On February 24, 2023, AMAC issued the updated Measures for Registration and Filing of Private Investment Funds (《私募投资基金登记备案办法》) (the "Measures") and the ancillary Guidelines No. 1-3 (i.e. Guideline on Basic Operational Requirements ("Guideline No. 1"), Guideline on Shareholders, Partners and Actual Controllers ("Guideline No. 2") and Guideline on Legal Representative, Senior Management Personnel, Executive Partner or Its Authorized Representative ("Guideline No. 3") (together with the Measures, the "New Rules"). The New Rules will take effect as of May 1, 2023.