The First 90 Days of a Chinese Company: A Recruitment, Payroll and Operations Launch Checklist

Start with the conclusion: the 90 days are an internal launch framework, not a uniform statutory deadline

The incorporation date is only the starting point of the internal checklist. The related obligations still run from their own trigger dates and cycles. Keep a management clock (Day 0–30, 31–60, 61–90) and a legal clock side by side, recording the employment date, the agreed payday, the entry date, permit expiry dates and the annual reporting period separately; no statutory obligation becomes uniform on day 90 as a result.

The 2026 edition of the Guide for foreign business people working and living in China from MOFCOM and other departments treats foreign work permits, residence, social insurance and individual income tax as separate matters. Local counters may differ, and the cards in this article are launch controls only. They do not promise registration, licensing, account opening, recruitment or onboarding outcomes.

The two-clock overview: write the trigger dates into the calendar first

The internal management clock can be laid out like this:

• Day 0–30: the entity becomes usable. Check the business licence, articles of association, business scope, registered address, legal representative and beneficial owners; complete the minimum connections for seals, banking, tax, invoicing, accounting and the authorisation matrix.
• Day 31–60: roles can be advertised. Build the role card, the candidate information notice and the budget first, then decide the onboarding route for a local or foreign employee; any business or role requiring a licence stops at the approval gate.
• Day 61–90: payroll is auditable and operations can be reviewed. Turn gross/net, individual income tax, social insurance, housing fund, pay receipts, supplier contracts, data security, insurance and accounting material into a monthly pack, and move the long-term dates onto the calendar.

The legal clock should record at least these trigger rules:

• Market entity registration covers one domicile or principal place of business; pre-approval licences must be obtained first, and post-approval licences must be granted before the activity starts. Having a business licence does not mean every activity can begin immediately; see the Regulation on the Administration of Registration of Market Entities.
• Social insurance unit registration is usually triggered by the incorporation date, while employee participation is triggered by the actual employment date, and the law sets 30-day rules for each; the incorporation date cannot stand in for the employment date. See the Social Insurance Law.
• The current housing fund rules set a 30-day registration period for newly established units, the order in which employee accounts are opened and related deadlines, all of which have to be checked against the local centre. Read the current Regulations on the Administration of Housing Provident Funds together with local practice.
• A written contract in principle has to be completed within one month of the employment date; wages are paid monthly on the agreed date; and individual income tax is usually declared and paid into the treasury within 15 days of the following month. The three have different start and end rules. See the Labour Contract Law, the wage payment Q&A and the Individual Income Tax Law.
• An enterprise registered in the current year files its annual report for the previous year between 1 January and 30 June of the following year; annual reporting follows that window and is not completed uniformly 90 days after incorporation. See the Interim Regulations on Enterprise Information Disclosure.
• Foreign employees get separate reminders for entry, accommodation registration, work permit and work-type residence: the 2026 guide notes that non-hotel accommodation is usually registered within 24 hours, residence is usually applied for within 30 days of entry, work permit renewal is usually 30 days in advance and information changes are usually amended within 10 working days. Individual documents and the local counter govern. See the 2026 edition of the guide.

Day 0–30: separate being able to operate, sign and pay

Action card 1: entity, licences and business scope

• Owner: the legal representative and the operations lead.
• Trigger: once the business licence, articles of association and business scope are available, or before starting a new activity.
• Due rule: before signing a contract that commits the company to delivering a service, advertising publicly or actually providing a licensed activity, check general items, pre-approval licences and post-approval licences one by one; do not treat the 90 days as a licence grace period. See the Company Law for entity governance.
• Evidence: business licence, articles of association, business scope checklist, licence list and written responses from the competent authority.
• Stop condition: the activity falls within a licensed item and the approval document is missing, expired or inconsistent with the entity.
• Next review: before each new product, region or advertising wording.

Action card 2: registered address and actual office

• Owner: the operations lead.
• Trigger: before choosing a site, signing a lease, preparing to recruit or receiving client data.
• Due rule: confirm first whether the registered domicile can be used, then confirm the fire safety, property management, visitor, equipment and employee safety conditions at the actual office; local rules for a domicile and for an actual place of business cannot be swapped on the strength of experience.
• Evidence: address use documents, the lease, property management confirmation, photos of the office and a risk list.
• Stop condition: the address cannot provide valid proof, or the office activity conflicts with property management, industry or fire safety conditions.
• Next review: on relocation, lease expansion, opening a branch or changing the use of the office.

Action card 3: seals, legal representative and payment authorisation

• Owner: the legal representative and the finance lead.
• Trigger: when seals are made, bank accounts, tax real-name verification and electronic tax bureau authorisation are set up.
• Due rule: build the separation-of-duties matrix for seal custody, seal requests, online banking preparation and review, invoicing and contract signing before letting a provider or employee touch physical seals, electronic seals or payment devices.
• Evidence: seal list, letters of authorisation, seal usage log, two-person online banking review records and revocation records.
• Stop condition: there is no traceable authoriser, reviewer or revocation mechanism, or one person can complete a contract, use the seal and make the payment alone.
• Next review: when management, bank operators, the outsourced finance provider or the office address changes.

Action card 4: banking, tax, invoicing and the accounting base

• Owner: the finance lead.
• Trigger: before the first receipt, payment, reimbursement, invoice or wage payment.
• Due rule: use the tax authority's new taxpayer service to check registration information, filing of the accounting system, reporting of deposit accounts, and the types and collection of invoices; where there is no genuine taxable transaction, do not issue an invoice just to get one out first.
• Evidence: bank account opening and account documents, tax information confirmation receipts, invoice approval, accounting system filing, the first business contract and invoice drafts.
• Stop condition: the receiving or paying account does not belong to the company, the invoice content does not match the genuine transaction, or the accounting voucher has no underlying business basis.
• Next review: on the first invoice, a change in the revenue model, a change in general taxpayer status or a change of bookkeeping provider.

The new taxpayer package covers information confirmation, accounting system filing, account reporting and invoice matters, but local processing times and invoice types still have to be checked. See the State Taxation Administration explanation. The Accounting Law requires books to be true and complete, and the first transaction should link the contract, delivery, payment, invoice and posting to one another. See the Accounting Law.

Action card 5: beneficial owners and the annual report calendar

• Owner: the legal representative and the company secretary or finance lead.
• Trigger: incorporation registration, changes in equity or control relationships, changes in the actual beneficial owner.
• Due rule: a newly established company usually files its beneficial owners at the time of incorporation registration; where that cannot be done at the same time, it is completed within 30 days after establishment. Where beneficial ownership changes, or the conditions for the promised exemption from filing no longer apply, update within 30 days of the change; check against articles 9 and 10 of the Measures and the registration system.
• Evidence: equity structure chart, the assessment record tracing through to natural persons, filing receipts, annual report drafts and the pre-publication review signature.
• Stop condition: equity, control and ultimate beneficial relationships cannot be explained, or the published data is inconsistent with the books, articles of association or actual transactions.
• Next review: on an equity transfer, a change of director or legal representative, financing, or each January.

The Measures for the Administration of Beneficial Owner Information took effect on 1 November 2024 and identify natural persons by ultimate ownership, actual control or entitlement to ultimate benefits; they are administered separately from the annual report.

Day 31–60: connect roles, candidates and the employment gate

Action card 6: role card and workforce budget

• Owner: the hiring manager and the finance lead.
• Trigger: deciding to hire, or to use dispatched or outsourced personnel.
• Due rule: before advertising, write down the work city, the employer entity, the reporting line, the work content, hours, probation, gross budget, benefits and whether a licence is involved; judge first whether the role touches a business licence or data permissions.
• Evidence: role card, budget version, approver, candidate scoring dimensions and recruitment channel list.
• Stop condition: it is unclear who the employer is or where the employee works, or the role's duties conflict with the business scope or licence conditions.
• Next review: before interviews, before a salary adjustment and when the business scope changes.

Action card 7: candidate personal information gate

• Owner: the recruitment lead and the personal information protection contact.
• Trigger: before receiving CVs, interview notes, background checks, identity documents, passports or health information.
• Due rule: state the recruitment purpose, the categories of information, the retention period, who has access and the third-party sharing arrangements first, and collect only the minimum needed to make the hiring judgement; where sensitive information or a cross-border HR system is involved, carry out a separate legality and security assessment.
• Evidence: recruitment privacy notice, consent or other lawful basis, access permissions, deletion deadlines, third-party processing agreements and deletion records.
• Stop condition: identity documents are spread through private chat groups, health or criminal information is collected without relevance, or an overseas head office wants to download full candidate files directly without an assessment.
• Next review: at the end of each recruitment round and when the recruitment platform or HR system changes.

Candidate information should have a clear and reasonable purpose and be limited to the minimum scope; a voluntary application does not mean it can be used indefinitely or shared with anyone. The Personal Information Protection Law, the Data Security Law and cross-border arrangements have to be reviewed together.

Action card 8: written contract and onboarding for a local employee

• Owner: the recruitment lead and a qualified employment law adviser or HR lead.
• Trigger: the actual employment date is confirmed, not the date the offer is issued.
• Due rule: the safest course is to sign a written labour contract before the employee starts work; the law allows a contract to be concluded within one month of the employment date if it is not signed at the same time, but that is not a basis for letting someone try the job first. The contract should state the employer, the work content and location, working hours and rest, labour remuneration, social insurance, the contract term and termination conditions.
• Evidence: the signed text, the copy held by the employee, the onboarding date, identity verification records, delivery of internal rules and training sign-in sheets.
• Stop condition: the employer entity is unclear, the pay basis is only "negotiable", there are no rules for changes of work location or role, or internships, outsourcing, dispatch and employment relationships are mixed up in the writing.
• Next review: on day 7 and day 30 after onboarding, and on any change of role or pay.

Articles 10 and 82 of the Labour Contract Law cover the one-month window and the risk of delay; see the Labour Contract Law. Where an employee refuses to sign, a written notice should be issued and the actual work performed should still be paid; labour already provided cannot be reduced to zero. The Implementing Regulations for the Labour Contract Law are the reference for handling a refusal to sign.

Action card 9: foreign employee permit gate

• Owner: the recruitment lead and the person handling the foreigner work permit.
• Trigger: a foreign national plans to work in mainland China in practice; at the same time, check whether the wage-paying entity, work location, employer and role match the documents.
• Due rule: before actual work begins, verify the work permit, work-type residence document, visa or other applicable document; build separate dates for long-term and short-term permits, city, employer, role and passport changes. Handle accommodation registration and residence points immediately after entry; renewals and information changes must not wait until the end of the 90 days.
• Evidence: passport and permit verification, work permit application material, the labour contract or employment proof, accommodation registration, residence document, approval receipts and expiry reminders.
• Stop condition: entry only on a business, tourist or visa-free basis without a permit that covers the actual work, or a work location, employer or role that does not match the permit.
• Next review: 24 hours after entry, 30 days after entry, on every change of role or passport, and 30 days before permit expiry.

The 2026 edition of the guide lists the usual work permit materials and points to the human resources and social security online platform, while the Exit and Entry Administration Law requires foreigners working in China to obtain a permit in accordance with the law. Whether an exception applies and which visa or residence document is needed is judged on the individual and by the local authority. Neither the National Immigration Administration nor the 2026 edition of the guide promises that an individual application will be approved.

Day 61–90: bring payroll, data and the supply chain into an auditable loop

Action card 10: payroll budget — gross, withholding and net

• Owner: the finance lead and the hiring manager.
• Trigger: when an offer fixes the salary, a contract is signed, or before the employee's first attendance.
• Due rule: budget in gross first, then estimate net from local social insurance, housing fund, individual income tax and the contract terms; record company-borne amounts and employee withholding separately rather than working backwards from take-home pay.
• Evidence: salary approval, the gross-to-net calculation, withholding authorisation, the employee payslip and the bank receipt.
• Stop condition: the salary is agreed only verbally or in chat, or payroll wrongly treats employee-borne items as company cost or mixes bonuses and reimbursements into wages.
• Next review: before each monthly pay run, and when salary, city or the social insurance and housing fund bases change.

Action card 11: social insurance, housing fund and local bases

• Owner: the finance lead and the HR lead.
• Trigger: company formation, actual employment, a foreign employee obtaining the applicable work permit, or an employee moving to a new city.
• Due rule: check unit social insurance registration against the 30-day rule from the incorporation date and employee registration against the 30-day rule from the employment date; check the housing fund against the current regulations for unit registration, the order of account opening and the local bases and ratios. See the Social Insurance Law.
• Evidence: unit registration receipts, employee participation records, housing fund unit and personal accounts, contribution declarations, employee details and exception handling forms.
• Stop condition: delaying wages that have already been earned simply because the system is not open yet, or replacing local Chinese rules with the benefit and withholding approach of the head office's country.
• Next review: after each monthly contribution, on a cross-city transfer, when a foreign employee's status changes, and around the date the 20 September 2026 rules take effect.

Timing needs special attention for the housing provident fund: the State Council published an amendment in August 2026, but the decision states expressly that it takes effect from 20 September 2026. As at this article's fact-check date of 24 August 2026, therefore, the amended content cannot be treated as the rule currently in force; check against the current regulations and the local centre first, then review again after 20 September. The amendment decision and the current regulations have to be kept separately.

Action card 12: payday, IIT and the rule that wages cannot stop

• Owner: the finance lead.
• Trigger: the employee has already provided labour and wages have arisen, or the contractual payday arrives.
• Due rule: pay on the agreed date, at least once a month, in line with the contract or lawfully adopted rules; once wages have arisen, pay them under the applicable basis first even if banking, tax, social insurance or housing fund procedures are not complete, and keep records of the later completion, supplementary filing and corrections. Withheld tax is usually declared and paid into the treasury within 15 days of the following month.
• Evidence: attendance or delivery records, the payroll sheet, payslips, bank receipts, individual income tax filing receipts, social insurance and housing fund contributions, and the variance adjustment sheet.
• Stop condition: undisputed wages that have fallen due are paid as normal; a disputed calculation or amount is recorded separately and handled in accordance with the law, and any statutory deduction or attachment follows a valid legal document; unfinished administrative account opening is not a reason to stop wages.
• Next review: within 3 working days after each pay cycle, with exceptions closed before the next cycle.

Gross is the contract and budget basis; net is the amount credited after lawful deduction of employee-borne items. The two cannot be merged into "monthly salary". The Labour Contract Law and the wage payment explanation require payment on the agreed date and at least monthly; individual income tax is declared under the withholding measures and other rules, and the withholding process should not become a condition for paying wages.

Action card 13: supplier contracts and insurance

• Owner: the operations lead and the finance lead.
• Trigger: before a lease, recruitment outsourcing, cloud service, bookkeeping, logistics, consultancy or other supplier starts delivering.
• Due rule: the contract should set out the entity, scope, acceptance, payment, invoicing, confidentiality, personal information processing, subcontracting, breach and exit; assess employer liability, property, public liability, cyber or professional liability insurance against the business risk, and do not present commercial insurance as uniformly compulsory for every company.
• Evidence: signed contract, supplier due diligence, acceptance sheets, invoices, policies, exclusions and the renewal calendar.
• Stop condition: the supplier refuses to explain data access or subcontracting, the party receiving payment differs from the party issuing the invoice, or a high-risk activity has no clear responsibility and insurance assessment.
• Next review: on the first payment, 30 days before renewal, on a supplier data incident, or when the business scope changes.

Action card 14: candidate and employee data, cyber security

• Owner: the operations lead and the IT or external security lead.
• Trigger: when the HR system, cloud drive, email, access control, payroll system or an overseas head office starts storing employee data.
• Due rule: build a data inventory, classification, least-privilege access, backup, logs, offboarding revocation and an incident contact; where cross-border transfer, important data, critical information infrastructure or large-scale personal information is involved, carry out a dedicated assessment first. Being a small company is not a reason to skip it.
• Evidence: data flow diagram, permission table, supplier security clauses, backup and recovery drills, incident log and deletion records.
• Stop condition: public links expose CVs or payroll sheets, shared accounts make accountability impossible, there is no backup, access survives departure, or overseas synchronisation has not been assessed.
• Next review: sample permissions monthly, run one drill each quarter, and reassess when a system or supplier changes.

The Data Security Law requires classified and graded protection according to importance, while the current Cybersecurity Law covers security responsibility, technical measures, logs and incident handling. A small team should start with least privilege, encrypted backups and access revocation, then have a professional check items such as outbound data transfer.

Action card 15: bookkeeping records and the monthly evidence pack

• Owner: the finance lead or the engaged bookkeeping firm, reviewed by the legal representative.
• Trigger: whenever revenue, cost, wages, taxes, assets, borrowing or a related-party transaction occurs.
• Due rule: obtain or create source documents based on genuine economic transactions, close the books monthly, and keep accounting vouchers, ledgers, statements, contracts, acceptances, invoices and bank statements; electronic records have to be able to prove version, source and access history.
• Evidence: the monthly voucher pack, general ledger details, bank reconciliation, invoice verification, payroll and tax filings, and related-party transaction notes.
• Stop condition: receipts or payments outside the books, company revenue collected through a personal card, payment without acceptance, invoices that do not match the business, or a bookkeeping firm that provides only statements and no underlying records.
• Next review: after each monthly close, before the quarterly management meeting, and before annual reporting, an audit or a tax inspection.

Action card 16: industry licences, workplace safety and the launch review

• Owner: the operations lead and the business lead.
• Trigger: the business moves from preparing to sell into actual delivery, or employees enter an office, warehouse, production or client site.
• Due rule: check pre-approval or post-approval licences, fire and safety training, special operation qualifications, client data and equipment risk item by item against the activity; employees engaged in production and business activities must not be put on the job before the required safety education and training is complete. The Work Safety Law sets out the training and record requirements.
• Evidence: licence matrix, licence documents, training sign-in and assessment, emergency contacts, equipment inspection and the incident reporting process.
• Stop condition: a licence is missing or expired, a hazardous post has no qualified person, or office exits or contractor safety responsibilities are unclear.
• Next review: each quarter and on every new device, site, role or activity.

Three launch sequences explicitly marked as fictional

The sequences below only demonstrate how to schedule work with the two clocks. The people, companies, dates and outcomes are fictional, are not client cases, and do not promise registration, licensing, account opening, recruitment or onboarding outcomes.

Fictional sequence A: a remote software team hires a local employee first

• Day 0–10: the founder locks down the business scope, registered address, seals and payment authorisation; finance builds a gross budget template.
• Day 11–30: operations confirms the actual office city, and the recruitment lead publishes the role card and completes the candidate information notice.
• Day 31–45: one local employee is selected, the contract is arranged for signature before the actual employment date, and the payday and payslip fields are set up.
• Legal clock: employee social insurance registration runs from the employment date, the contract window runs from the employment date, and individual income tax runs from the filing cycle after wages are paid; the three dates are recorded separately.

Fictional sequence B: an overseas founder plans to be in China for operations

• Day 0–20: the company works only on the role and document list and does not automatically treat business visits, visa-free entry or short meetings as employed work.
• Day 21–50: the handler prepares the contract, academic or professional qualifications, criminal record check, medical examination and passport materials under the 2026 edition of the guide, and checks the applicable route with the competent authority.
• Day 51–90: reminders are set from the actual dates of entry, accommodation registration, work permit and work-type residence document; no actual work is arranged before the permit gate is cleared.
• Boundary: the sequence only explains the order of control. It does not mean any application will be approved or completed within a given number of days.

Fictional sequence C: an asset-light office needing invoices and suppliers

• Day 0–15: operations verifies the registered domicile and office first, while finance completes the list of tax information, accounts and invoicing needs.
• Day 16–45: the contract template adds acceptance, invoicing, data access, confidentiality, subcontracting and insurance assessment; no payment goes out before supplier due diligence is complete.
• Day 46–90: a monthly pack is formed for revenue, procurement, wages, taxes and bank reconciliation; where the transaction entity, invoice or data permission is inconsistent, that process stops and is escalated.
• Boundary: this sequence invents no clients, amounts, office locations or business results, and promises no account opening, invoicing, supplier signing or business launch.

The post-90-day review pack: turn a short launch into ongoing management

Day 90 is only the first review: monthly close, payroll, individual income tax, social insurance, housing fund and permissions; quarterly checks of suppliers, insurance, safety, licences and data backup; annual reporting between 1 January and 30 June of the following year; and work permits, residence, insurance and contracts reviewed against their expiry dates.

If the company's equity, controller, legal representative, registered address, bank authorisation, roles, work locations or business scope changes, write the change date into the legal clock and reassess whether filing, amendment, supplementary declaration, contract re-signing or permit updates are needed. Do not let a static table headed "90 days after incorporation" cover those events.

Within a clearly defined scope, MANPRPOWER LIMITED can assist with registration coordination, document preparation and content organisation. Judgements involving employment, tax, data, immigration or industry licensing still belong with qualified local professionals and the competent authorities.