India Entry for Chinese Companies
AU Corporate helps Chinese and China-linked companies navigate India's Press Note 3 approval framework, structure compliant FDI, and manage the beneficial ownership documentation that determines which route applies.
FDI from China into India is governed by a materially different framework than most other countries — Press Note 3 (2020) requires prior government approval for investment from any entity where the beneficial owner is situated in, or a citizen of, a country sharing a land border with India, China included. This is not a formality: understanding exactly which route your specific investment falls under is the single most important early decision for a China-linked India entry.
Our team includes Utsav Dogra, FCA, with direct experience managing outsourcing and Virtual CFO engagements for Indian subsidiaries of Chinese corporate groups — and Rimpi Jain, Company Secretary, who handles the FEMA and RBI approval filings this specific route requires.
What Changed in 2026 — And What Didn't
The March 2026 Amendment
India's Union Cabinet approved amendments to Press Note 3 on March 10, 2026 (notified as Press Note 2, 2026 series, effective May 1, 2026). Global entities with up to 10% non-controlling Chinese beneficial ownership can now use the automatic route, subject to sectoral caps — a narrow but real opening after six years of blanket approval requirements.
What Still Needs Approval
Direct investment from entities incorporated in China or Hong Kong, and any investment involving control or majority ownership, still requires prior government approval regardless of stake size — the 2026 amendment did not remove this.
60-Day Fast Track
A defined list of priority manufacturing sectors — including capital goods, electronic components, and polysilicon/ingot-wafer manufacturing — qualifies for a 60-day approval timeline, provided majority ownership and control remain with Indian residents.
Beneficial Ownership Mapping
Press Note 3 looks through the full ownership chain, not just the direct investor — a global fund or holding company with Chinese beneficial ownership above the threshold can trigger approval requirements even if the investing entity itself isn't Chinese. This mapping exercise needs to happen before you file, not after.
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