A Unified Cash Pool Takes Shape: China Extends RMB–Foreign Currency Management Framework for Multinational Groups
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On 26 December 2025, the People’s Bank of China (PBC) and the State Administration of Foreign Exchange (SAFE) jointly released a circular extending nationwide a unified cash pooling framework for multinational corporations, integrating RMB and foreign-currency fund management under a single regulatory structure. The policy, effective immediately, builds on earlier regional pilot programmes.
The framework allows eligible multinational groups to centrally operate domestic and offshore funds, covering cash concentration, internal liquidity balancing, centralized settlement of current-account transactions, and periodic netting arrangements. RMB-denominated operations are explicitly encouraged, while regulatory filings and subsequent changes are consolidated under a single local SAFE contact point to reduce procedural complexity.
Participation is limited to corporate groups connected through equity ownership. Financial institutions, local government financing vehicles, and real estate companies are excluded, except where a licensed finance company serves as the designated host entity. Each participating group must appoint a domestic host company, responsible for registration, execution, data reporting, and ongoing compliance.
Eligibility is subject to defined quantitative thresholds, including minimum levels of cross-border receipts and payments, consolidated revenues for domestic and overseas entities, and a clean recent compliance record. Domestic and overseas participation must involve no fewer than three group entities.
A central element of the framework is quota-based management of both external borrowing and overseas lending. Aggregate quotas are calculated using audited equity figures of participating entities, combined with regulatory leverage ratios and macroprudential adjustment parameters. Within approved limits, funds may be allocated flexibly across the group, while cross-currency arbitrage between RMB and foreign currencies is prohibited.
The framework also permits centralized current-account settlement and netting of receivables and payables among affiliates, generally conducted on a monthly basis. Groups meeting relevant criteria may apply existing trade and investment facilitation measures, subject to bank and enterprise eligibility under prevailing rules.
Operationally, the host company must open a domestic master cash pool account with a qualified onshore bank. The account may be multi-currency, may allow intraday and overnight overdrafts for external payments, and serves as the primary channel for borrowing, lending, settlement, and foreign exchange conversion, within clearly defined usage scopes and negative lists for capital-account funds.
Regulatory oversight combines ongoing data monitoring with post-event supervision. Banks and enterprises are required to retain transaction documentation for five years and comply with customer due diligence and anti-money laundering obligations. Multinational groups operating under this framework may not run parallel cross-border cash pooling schemes; a one-year transition period is provided for groups migrating from existing arrangements.






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