Why NRA Account Opening Requires RPIC Application? A Deep Analysis of the Process and Details

Why is an Application for Round-Trip Investment Required to Open an NRA Account? A Detailed Analysis of the Process and Details

In recent years, with the rapid economic development and rising international status of China, more and more Chinese enterprises have chosen to go global by making overseas investments or setting up branches abroad. At the same time, to meet cross-border business needs, many companies have registered offshore companies and opened Non-Resident Accounts NRAs. However, in practice, many enterprises have found that when they plan to repatriate these offshore funds back to China for investment or other purposes, they often need to submit additional round-trip investment applications. So why does this situation occur? This article will provide a detailed analysis of this issue from the perspectives of policy background, specific processes, and precautions.

Background Analysis The Necessity of Round-Trip Investment

Round-trip investment refers to the behavior of overseas enterprises or individuals reinvesting their held funds or assets into the domestic market through various means. In the field of foreign exchange management, the core purpose of round-trip investment is to prevent capital flight and illegal money laundering, while ensuring effective regulation of national foreign exchange liquidity. When overseas enterprises or individuals wish to use funds in their NRA accounts to carry out related activities within China, they must first go through an approval process, i.e., submitting a round-trip investment application.

For example, at the beginning of 2025, a foreign-funded enterprise was required to provide detailed round-trip investment materials due to its plan to use funds from its Hong Kong subsidiary account to participate in real estate project development in mainland China. This indicates that regardless of the nature of the enterprise, as long as it involves the flow of funds to specific areas in China, relevant regulatory requirements must be followed.

Main Components of the Round-Trip Investment Application

According to current regulations, round-trip investment applications typically include the following aspects

1. Subject Qualification Certificate Applicants need to submit registration documents of the offshore company, shareholder structure explanation, and information about the actual controller. The aim is to confirm whether the applicant has a legitimate identity and the right to control the relevant funds.

2. Proof of Fund Sources This is the most important part of the round-trip investment application. Enterprises need to provide bank statements, financial statements, and other materials that can substantiate the legality of the funds. For instance, if a company raises a large sum of funding after listing overseas, it needs to explain to the regulatory authorities the specific use and legality of this funding.

3. Details of Investment Projects Including the name, scale, and expected returns of the proposed investment projects. It is also necessary to clarify whether the investment aligns with national industrial policy guidance, and whether there are any potential risk points.

4. Other Supplementary Materials Such as opinion letters issued by the commerce authority and legal opinions issued by law firms. These documents can further enhance the authority and credibility of the application materials.

Process Explanation From Submission to Approval

The overall process of the round-trip investment application can roughly be divided into four stages preparation stage, submission stage, review stage, and final approval stage.

1. Preparation Stage

During this period, enterprises should organize professional teams to comprehensively sort out the required materials to ensure that every document is accurate and error-free. It is worth noting that different regional foreign exchange bureaus may have different emphases, so it is recommended to consult local institutions in advance to obtain the latest requirements.

2. Submission Stage

After completing the preparations, enterprises can submit complete application materials through online systems or offline windows. Currently, most regions have opened electronic declaration channels, greatly improving work efficiency. However, for enterprises encountering this business for the first time, attention should still be paid to issues such as format standardization.

3. Review Stage

After receiving the application, the foreign exchange management department will assign specialists to verify the provided materials one by one. This process may last for several weeks or even longer, during which new evidence may be requested or certain details clarified. Maintaining good communication with relevant departments is crucial.

4. Final Approval Stage

Once the review is passed, the foreign exchange administration bureau will formally approve the round-trip investment application and notify the enterprise to collect the approval document. Thereafter, the enterprise can proceed with subsequent operations according to the predetermined plan.

Precautions Avoid Common Misunderstandings

Although the round-trip investment application seems complex, it is not difficult to achieve as long as the correct methods are mastered. Here are some points to note

Firstly, do not attempt to bypass the regulatory mechanism out ofpsychology. In recent years, China has continuously increased efforts to crack down on violations. Once false declarations are verified, not only will the progress of the current project be affected, but future similar businesses may also be restricted.

Secondly, plan the time nodes reasonably. Since round-trip investment involves coordination among multiple departments, the entire process takes a long time. Therefore, it is suggested to start the preparation procedure as early as possible to avoid delaying subsequent arrangements.

Finally, hire professionals to assist in handling related matters. Whether writing application reports or responding to review stages, experienced service teams can save enterprises a lot of effort and costs.

In conclusion, the requirement for NRA account opening to involve a round-trip investment application is not without reason, but rather a necessary measure based on considerations of financial security and social stability. For enterprises intending to engage in such businesses, only by fully understanding relevant policies and regulations and strictly adhering to the rules can they successfully achieve their goals.