Regulations on Administration of Foreign–Invested Construction Enterprises

文章摘要 本文系统规定了外商投资建筑业企业的设立与资质管理,明确外商独资、中外合资、中外合作三类形式,须取得商务批准、工商登记和建设资质后方可经营。实行分级分类审批:特级或一级总承包及一级专业承包资质由国务院商务与建设部门审批,二级及以下资质由省级部门审批。设立程序上,省级商务部门30日内初审,国务院商务部门转建设部门审查,后30日内决定,获准后30日内登记,再申请资质。为企业进入中国建筑市场提供清晰合规路径。

Chapter 1 General provisions

Article 1 These Regulations hereof are formulated to further the opening up to the outside and standardise the administration of foreign-invested construction enterprises in accordance with such laws and regulations as the Construction Law of the People’s Republic of China, the Tendering and Bidding Law of the People’s Republic of China, the Law of the People’s Republic of China on Sino-foreign Equity Joint Ventures, the Law of the People’s Republic of China on Sino-Foreign Cooperative Joint Ventures, the Law of the People’s Republic of China on Wholly Foreign-Owned Enterprises and the Regulations on Administration of Construction and Engineering Quality.


Article 2 These regulations shall apply to the establishment of foreign–invested construction enterprises within the territory of the People’s Republic of China, the application for construction enterprise qualifications and the administration and supervision of foreign–invested construction enterprises.


The term ‘foreign-invested construction enterprise’ mentioned in these regulations refers to a wholly foreign-owned construction enterprise, or a Sino-foreign equity construction joint venture or a Sino-foreign cooperative construction enterprise established within the territory of the People’s Republic of China in accordance with Chinese laws and regulations.


Article 3 A foreign investor, which intends to establish a foreign-invested construction enterprise within the territory of the People’s Republic of China and conduct construction business, shall, in accordance with laws, obtain the approval certificate from the relevant foreign trade and economic cooperation administration department and register with the State Administration of Industry and Commerce or its authorised administration of industry and commerce at local levels, and the qualification certificate from the relevant construction administration department.


Article 4 Foreign-invested construction enterprises which engage in construction business within the territory of the People’s Republic of China shall abide by the laws, regulations and rules of the People’s Republic of China.



The lawful operation of foreign-invested construction enterprises and their legal rights and interests within the territory of the People’s Republic of China shall be protected by Chinese laws, regulations and rules.


Article 5 The foreign trade and economic cooperation administration department of the State Council shall be responsible for the administration of the establishment of foreign-invested construction enterprises. The construction administration department of the State Council shall be responsible for the administration of the qualifications of foreign–invested construction enterprises.


The foreign trade and economic cooperation administration departments of the people’s government of provinces, autonomous regions or directly administered municipalities shall be responsible for the administration of the establishment of foreign-invested construction enterprises within their authorised jurisdiction; the construction administration departments of the people’s government of the provinces, or autonomous regions or directly administered municipalities shall, in accordance with these Regulations, be responsible for the administration of qualifications of foreign–invested construction enterprises within their administrative regions.


Chapter 2 Application for and Examination and Approval of Establishment of Foreign–invested Construction Enterprises and their Qualifications


Article 6 The application for and the examination and approval of the establishment of foreign-invested construction enterprises and their qualifications shall be managed by a grading and categorization system.


Where an applicant is to apply to establish a contractor with Super Grade or Grade A qualifications or to establish a specialised contractor with Grade A qualifications, the establishment of the foreign-invested construction enterprise shall be examined and approved by the foreign trade and economic cooperation administration department of the State Council and its qualifications shall be examined and approved by the construction administration department of the State Council; where an applicant is to apply to establish a contractor or a specialised contractor with Grade B or lower qualifications or any of the subcontractor qualifications, the establishment of the foreign–invested construction enterprise shall be examined and approved by the foreign trade and economic cooperation administration department of the people’s government of the province, the autonomous region or the directly administered municipality and its qualifications shall be examined and approved by the construction administration department of the people’s government of the province, the autonomous region or the directly administered municipality.


Where the Chinese investor to a proposed Sino-foreign equity construction joint venture or a Sino-foreign cooperative construction enterprise is an enterprise administered by the central government, the establishment of the joint venture shall be examined and approved by the foreign trade and economic cooperation administration department of the State Council and its qualifications shall be examined and approved by the construction administration department of the State Council.


Article 7 The procedures for the establishment of a foreign–invested construction enterprise as a contractor with Super Grade or Grade A qualifications or a specialised contractor with Grade A qualifications are:


(1) The applicant shall submit an application to the foreign trade and economic cooperation administration department of the people’s government of the province, the autonomous region or the directly administered municipality where the proposed foreign-invested construction enterprise is to be established.


(2) The foreign trade and economic cooperation administration department of the people’s government of the province, the autonomous region or the directly administered municipality shall complete the preliminary examination within 30 days of receiving the application, and shall, if it grants the preliminary approval, submit the application to the foreign trade and economic cooperation administration department of the State Council for further approval.


(3) Within 10 days of receiving the application for further approval, the foreign trade and economic administration department of the State Council shall forward the application to the construction administration department of the State Council for review and comments. The construction administration department of the State Council shall provide its opinion in writing within 30 days of receiving the request. Within 30 days of receiving the response, the foreign trade and economic cooperation administration department of the State Council shall decide whether or not to approve the application and express such a decision in written form. If the application is approved, a foreign-invested enterprise certificate shall be granted; if the application is not approved, reasons for the disapproval shall be given in written form.


(4) Within 30 days of receiving the approval certificate, the applicant shall register with the relevant registration department.


(5) After obtaining the business license for the legal entity, the application by the foreign-invested construction enterprise for qualification approval shall be conducted in accordance with Regulations on Administration of Construction Enterprise Qualifications.


Article 8 The procedures for the establishment of a foreign-invested construction enterprise as a contractor or a specialised contractor with Grade B or lower qualifications or any of the subcontractor qualifications shall be administered by the construction administration department and the foreign trade and economic cooperation administration department of the people’s government of the province, the autonomous region or the directly administered municipality based on local conditions with reference to Article 7 of these Regulations and Regulations on Administration of Construction Enterprise Qualifications.


Examination and approval of qualifications of the foreign-invested construction enterprise by the construction administration department of the people’s government of the province, the autonomous region or the directly administered municipality shall be filed with the construction administration department of the State Council within 30 days after the approval is given.


Article 9 The application by a foreign-invested construction enterprise for upgrading its qualifications or adding additional qualifications in addition to major items shall be made to the relevant construction administration department in accordance with relevant regulations.


Article 10 An applicant which intends to establish a foreign-invested construction enterprise shall submit the following documents to the relevant foreign trade and economic cooperation administration department:


(1) Application forms to establish a foreign-invested construction enterprise signed by the investor’s legal representative;


(2) The feasibility study report prepared or accepted by the investors;


(3) The contract for the establishment of a foreign-invested construction enterprise and the articles of association signed by the investor’s legal representative (only the articles of association is required for the establishment of a wholly foreign-owned construction enterprise);


(4) The notification on pre-verification of the name of the enterprise;


(5) Documentary evidence of legal entity registration and bank credential letter of the investor;


(6) Appointment letters and documentary evidence of the investor’s designated chairman and members of the board of directors, managers and technical managers etc.; and


(7) Balance sheets and profit and loss accounts of the investor over the past three years audited by a certified accountant or an accounting firm.


Article 11 The applicant applying for foreign-invested construction enterprise qualifications shall submit the following documents to the relevant construction administration department:


(1) Application forms for the foreign-invested construction enterprise qualifications;


(2) The approval certificate for the establishment of the foreign-invested construction enterprise;


(3) The business licence for the legal entity;


(4) The bank credential letter of the investor;


(5) Appointment letters and documentary evidence of the investor’s designated chairman and members of the board of directors, the enterprise’s financial manager, operations managers and technical managers etc.; and


(6) Balance sheets and profit and loss accounts of the investor over the past three years audited by a certified accountant or an accounting firm.


(7) Other documents required


Article 12 The total capital contribution of the Chinese party to a Sino-foreign equity construction joint venture or a Sino-foreign cooperative construction enterprise shall not be less than 25% of the registered capital.


Article 13 Qualifications of Sino-foreign equity construction joint ventures and Sino-foreign cooperative construction enterprises established prior to the issuance of these Regulations are required to be re-examined and ratified in accordance with these Regulations and Regulations on Administration of Construction Enterprise Qualifications.


Article 14 All documents required to be submitted by an applicant under these Regulations shall be in Chinese. If the original documentary evidence is in a foreign language, a Chinese translation shall be provided.

Chapter 3 Scope of Contracting

Article 15 Wholly foreign-owned construction enterprises may only undertake the following types of construction projects within the scope of their qualifications:


(1) Construction projects funded totally by foreign investments, foreign grants or foreign investments and grants;


(2) Construction projects financed by international financial organisations and awarded through international tendering process in accordance with the provisions of the loan agreement;


(3) Sino-foreign jointly constructed projects where the foreign investment is equal to or greater than 50%; Sino-foreign jointly constructed projects where the foreign investment is less than 50% but which Chinese construction enterprises cannot undertake independently due to technical difficulties subject to the approval of the construction administration departments of the people’s government of provinces, or autonomous regions or directly administered municipalities;


(4) China-invested construction projects which Chinese construction enterprises cannot undertake independently due to technical difficulties. Such projects may be jointly undertaken by Chinese and foreign construction enterprises subject to the approval of the construction administration departments of the people’s government of provinces, or autonomous regions or directly administered municipalities.


Article 16 Sino-foreign equity construction joint ventures and Sino-foreign cooperative construction enterprises shall undertake construction projects within the permitted scope of their grades of qualifications.

Chapter 4 Supervision and Administration

Article 17 The criteria of grading of qualifications of foreign-invested construction enterprises shall be in accordance with the criteria of grading of construction enterprise qualifications formulated and issued by the construction administration department of the State Council.


Article 18 Where a foreign-invested construction enterprise undertakes a construction project as the contractor, it shall itself complete the main structure of the project.


Article 19 Where a foreign-invested construction enterprise contracts for construction projects in the form of a consortium with other construction enterprises, the consortium shall contract for projects within the permitted scope of the lower qualification grade.


Article 20 Where a foreign-invested construction enterprise contracts for construction projects beyond the permitted scope of its qualifications in violation of Article 15 of these Regulations, a fine at an amount between 2% to 4% of the construction contract price shall be collected. An order to suspend its business operation and to correct the wrongdoings may also be issued and its qualification certificate may be demoted. In serious situations, the qualification certificate shall be revoked and any proceeds illegally obtained shall be confiscated.


Article 21 Where a foreign-invested construction enterprise carrying out construction business violates the Construction Law of the People’s Republic of China, the Tendering and Bidding Law of the People’s Republic of China, Regulations on Administration of Engineering Construction Quality and Regulations on Administration of Construction Enterprise Qualifications and other relevant laws, regulations and rules, it shall be penalised in accordance with relevant provisions.

Chapter 5 Supplemental Provisions

Article 22 For a foreign enterprise which has already obtained a Foreign Enterprise Qualification Certificate for Contracting for Construction Projects prior to these Regulations come into force, it may apply for a construction enterprise qualification of an appropriate grade based on its track record of project contracting within the territory of the People’s Republic of China when establishing a foreign-invested construction enterprise.


Where a foreign enterprise which has already established a foreign invested construction enterprise within the territory of the People’s Republic of China as stated in Paragraph 1 of this Article is to establish a new foreign-invested construction enterprise, the qualification grade of the new foreign-invested construction enterprise shall be determined in accordance with Regulations on Administration of Construction Enterprise Qualifications.


Article 23 Investors from Hong Kong Special Administrative Region, Macao Special Administrative Region or Taiwan shall establish construction enterprises and carry out construction businesses in other provinces, autonomous regions or directly administered municipalities in accordance with these Regulations, unless it is otherwise provided by laws, regulations or the State Council.


Article 24 The construction administration department of the State Council and the foreign trade and economic cooperation administration department of the State Council shall be responsible for interpretation of these Regulations in accordance with their respective functions.


Article 25 These Regulations shall come into force on 1 December 2002.


Article 26 The Tentative Measures on Administration of Foreign Enterprise Qualifications for Contracting for Construction Projects Within the Territory of China issued by the Ministry of Construction (Decree No. 32 of the Ministry of Construction) shall be repealed as of 1 October 2003.


Article 27 Provisions on Establishment of Foreign-invested Construction Enterprises (File No. 533, 1995) jointly issued by the Ministry of Construction and the Ministry of Foreign Trade and Economic Cooperation shall be repealed as of 1 December 2002.

杨春宝一级律师简介

杨春宝一级律师,大成上海高级合伙人、资本市场部主任、国资基金研究中心主任,大成中国区私募基金专业带头人、科技与文化法律研究中心联合牵头人。执业30余年,长期从事私募基金、投融资、并购重组法律服务,尤其对对赌研究颇深且具有非常丰富的实战经验,并专注于金融机构股权投资业务。2004年起多次入选The Legal 500"私募基金"和"公司与商业"等境内外各类律师榜单,代理的中国法院首例适用外国法律审理外国公司的董事损害小股东权益纠纷案入选上海高院发布的《上海法院域外法查明典型案例》和威科先行"要案头条"。入选上海涉外法律人才库、上海市司法局鼎新法治人才库、上海国有企业改制法律顾问团,具有上市公司独立董事任职资格,系多家知名高校的兼职教授或兼职研究生导师及上海市商务委跨国经营人才培训班讲师。出版《私募股权投资基金风险防控操作实务》等16本投融资法律专著。了解更多

常见法律问题

外商投资建筑业企业设立需经过哪些步骤?

①法律概念与规则解释:外商投资建筑业企业指外国投资者在中国境内依法设立的全资、中外合资或合作建筑企业。依据现行管理制度,企业设立需取得商务部门审批证书、工商营业执照,并取得建设主管部门颁发的资质证书,方能承接建筑业务。相关规则强调审批、登记和资质管理三个环节,缺一不可。②案件事实与实务场景引用:按照本规定,拟设立特级或一级总承包资质企业的,申请人先向拟设地省级商务部门提交申请,省级部门30日内完成初审;初审通过的,转报国务院商务部门,后者10日内送建设部门审查,建设部门30日内出具意见,商务部门30日内决定是否批准。批准后30日内办理工商登记,再按资质管理规定申请资质。由此可见,全过程时限有明确约束。③实务指引与风险提示:实务中常见问题包括材料不齐导致初审延误,以及未在获得批准后及时办理登记和资质申请。建议企业提前准备可行性报告、合资协议等文件,并关注商务、建设两部门衔接节点,避免因错过时限而影响项目启动。同时应确保外资比例和经营范围符合产业政策,防止后续合规风险。

外商投资建筑业企业资质审批如何分级分类?

①法律概念与规则解释:分级分类管理是外商投资建筑业企业资质审批的核心制度,即根据企业拟申请资质等级和类别,由不同层级的主管部门分别行使审批权。总承包特级、一级和专业承包一级由国务院商务和建设部门审批;总承包或专业承包二级及以下、以及劳务分包资质由省级商务和建设部门审批。此种安排兼顾开放与监管效率。②案件事实与实务场景引用:本规定明确要求,若属于特级或一级资质申请,须先经省级商务部门初审,再报国务院商务部门,由其转请国务院建设部门提出审查意见,最终由国务院商务部门作出批准决定。而二级及以下资质申请,则完全由省级部门审批,程序相对简捷。这一划分直接影响企业申报路径和时间成本。③实务指引与风险提示:企业应首先明确拟申请资质等级,选择对应审批层级与申报渠道。高等级资质审批链条长、环节多,建议预留至少3个月审批周期;低等级资质审批相对较快,但省级部门口径可能略有差异。企业还应关注资质标准中的人员、业绩要求,避免因条件不满足而被退回,导致审批周期延长。

外商投资建筑业企业取得资质证书需要什么条件?

①法律概念与规则解释:资质证书是评价建筑企业综合实力的法定凭证,也是承揽工程的前提。外商投资建筑业企业申请资质,与其他内资企业一样,需符合建设主管部门制定的企业资质标准,包括企业资产规模、主要人员配备、已完成工程业绩等条件。取得资质后方可在许可范围内从事相应等级的工程承包活动。②案件事实与实务场景引用:本规定指出,在获得商务部门批准证书并完成工商登记后,外商投资建筑业企业应按照建设企业资质管理规定申请资质核准。对于不同等级资质,审批层级不同:特级、一级由国务院建设部门核准;二级及以下由省级建设部门核准。这表明资质条件与等级挂钩,高等级资质对应更严格的审查要求。③实务指引与风险提示:实务中,建议企业对照拟申报等级的标准逐项自检,特别是人员证书归属社保关系、业绩证明材料是否齐全。一旦发现条件不达标,应调整申请等级,避免浪费审批时间。还需注意资质证书有效期满后的延续申请,以及日常经营中的动态核查,防止因资质条件变化导致被撤回证书。

以上内容仅供参考,不构成法律意见。如需专业法律服务,请联系杨春宝一级律师:chambers.yang@dentons.cn

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