来源：君合法律评论
发布日期：2026年03月17日
The China Securities Regulatory Commission (CSRC) recently approved four Hong Kong-domiciled funds for publicly offering in Chinese mainland as mutual recognition of funds (MRFs). This is another batch of Hong Kong MRFs approved since the revised Administrative Provisions on the Mutual Recognition of Funds between the Mainland and Hong Kong ('the Administrative Provisions') came into effect on January 1, 2025. The four newly approved products include two equity-type funds and two bond-type funds. The launch of these new products further enriches cross-border fund investment channels. They provide mainland investors with more options to participate in overseas markets and offer new tools for diversified asset allocation.
Under the current regulatory framework, unit trusts, mutual funds, and other types of collective investment schemes that are established and operated under the laws of the Hong Kong Special Administrative Region and offered to the public in Hong Kong may, after being registered with the CSRC, be sold to local retail investors. This originated from the 'Memorandum of Regulatory Cooperation concerning Mutual Recognition of Funds between the Mainland and Hong Kong' that was signed in 2015 between the CSRC and the Securities and Futures Commission of Hong Kong (SFC). Since its implementation, the scheme has operated steadily for many years and has become an important system connecting the public fund markets of the two jurisdictions.
In recent years, as mainland investors’ demand for global asset allocation has increased, MRFs have attracted growing interest in the market. In order to further improve the regulatory framework, the CSRC revised the Administrative Provisions in December 2024, with the revised version taking effect on January 1, 2025. The revised Administrative Provisions introduced several improvements. Firstly, in terms of sales ratios, the revised Administrative Provisions relaxed the limit on the sales ratios of MRFs in the mainland market, increasing the cap from the previous 50% to 80%, thereby providing greater scope for MRFs to expand their distribution scale in the mainland market. Secondly, the revised Administrative Provisions relaxed the restrictions on the delegation of investment management functions, allowing fund managers, where the regulatory conditions are met, to delegate certain investment management functions to overseas affiliated institutions within the same group. Thirdly, the revised Administrative Provisions added 'other types of funds recognized by the CSRC' as a category of products that may be included in the mutual recognition scheme, thereby reserving room for the regulatory expansion of more types of offshore fund products to be incorporated into the mutual recognition framework in the future.
The sales scale of MRFs in the mainland market has grown steadily in recent years. According to statistics released by the State Administration of Foreign Exchange (SAFE), as of the end of January 2026, the cumulative net capital outward remittance associated with the distribution of Hong Kong funds in Chinese mainland has reached approximately RMB 126 billion and has remained above RMB 120 billion over the past six months. As the sales expands, an increasing number of global asset management firms are using MRFs as a key strategic component in their China business planning. Under the current regime, only funds registered and established in Hong Kong are eligible to apply as Hong Kong MRFs for public offering in Chinese mainland. Consequently, a market trend has emerged wherein more foreign asset managers are launching public funds registered in Hong Kong to prepare for participation in the mutual recognition scheme, with the goal to enter the mainland market through this scheme, in due course.
Based on regulatory review practice, regulators focus on multiple factors when reviewing applications for MRFs, including the size of the fund product in the overseas market, its historical performance, the stability of the investment strategy and style, the investor structure, and the proposed local distribution arrangements. Regulatory authorities will require overseas fund managers to fully demonstrate whether the product is consistent with the strategic positioning of 'inclusive finance', in light of its intended local distribution target investors. Under this regulatory approach, overseas fund managers need to make thorough preparations in product design, information disclosure, risk management, and distribution arrangements in order to ensure compliance and the prudent operation of the products.
With the improvement of the regulatory framework and the growth in demand, the position of mutual recognition schemes in the cross-border asset allocation system is expected to strengthen further. For overseas asset management firms, the mutual recognition scheme provides an important channel to access the local public fund market and an opportunity to introduce mature overseas investment strategies into the mainland market. Along with the evolution of regulatory requirements regarding compliance operations and risk management, overseas firms participating in the mutual recognition scheme are advised to devote more resources to compliance management and product governance, in order to adapt to China’s regulatory environment and investor protection requirements.
Natasha XIE
Partner
Practice Area
Foreign Direct Investment
Banking and Finance
Capital Market
Austin ZHANG
Partner
zhangchi_austin @junhe.com
Practice Area
Asset Management
Securities Investment Funds
Foreign Direct Investment
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