As the largest coastal open city in northern China, Tianjin is one of the first batch of Qualified Foreign Limited Partner (“QFLP”) pilot cities. For a long time after As the largest coastal open city in northern China, Tianjin is one of the first batch of Qualified Foreign Limited Partner (QFLP) pilot cities. For a long time after the launch of the QFLP pilot policy, the primary regulatory framework governing the implementation of the Tianjin QFLP Pilot Scheme was the “Interim Measures for the Pilot Scheme of Foreign-invested Equity Investment Enterprises and their Management Institutions in Tianjin” (《关于本市开展外商投资股权投资企业及其管理机构试点工作的暂行办法》), issued in October 2011. After more than a decade of development, foreign investors have increasingly sought more diversified and flexible investment methods and structures when allocating capital to Chinese assets. Against this backdrop, and on the basis of analysis of past experience in implementing the QFLP pilot policy, Tianjin Binhai New Area (天津滨海新区) — as a national-level new area and a crucial strategic hub for the coordinated development of Beijing-Tianjin-Hebei region — promulgated the “Tianjin Binhai New Area Qualified Foreign Limited Partner (QFLP) Pilot Scheme Measures” (《天津滨海新区合格境外有限合伙人试点办法》) (“New Regulations”) on April 6, 2025. The New Regulations aim to further optimize the foreign investment environment, enhance financial openness in the region, and encourage and guide QFLPs in developing equity investment and the venture capital (VC) funds market. The New Regulations cover five development zones in the Tianjin Binhai New Area, including the Tianjin Economic and Technological Development Zone (天津经济技术开发区), the Tianjin Port Free Trade Zone (天津港保税区), the Tianjin Binhai High-tech Industrial Development Zone (天津滨海高新技术产业开发区), the Tianjin Dongjiang Comprehensive Free Trade Zone (天津东疆综合保税区) and the Sino-Singapore Tianjin Eco-city (中新天津生态城). With a focus on being “more open, more flexible and more efficient”, the New Regulations have introduced several innovative measures, offering foreign capital a new pathway to participate in China’s equity investment market.
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I. Key Highlights of the New Regulations
Following the release of the New Regulations, we conducted an in-depth review and briefly summarize the five key policy highlights as follows:
II. Policy Impact of and Future Outlook for the New Regulations
Several groundbreaking provisions in the New Regulations provide a major boost for foreign capital investment in China. These changes not only allow foreign investors to utilize pure offshore structures to deploy capital into China without being constrained by domestic fundraising filing requirements but also expand the investment scope through the Tianjin Binhai QFLP Pilot Fund (天津滨海QFLP试点基金), which will encourage foreign investors to unlock more value of existing domestic assets.
However, some provisions of the New Regulations remain principle-based or framework-oriented, such as the specific application requirements for Tianjin Binhai QFLP Pilot Fund, which is structured as a contractual fund, and the detailed documentary requirements and procedures for the QFLP Pilot Scheme. We hope that the Tianjin Binhai New Area will soon issue operational guidelines on these and other matters to facilitate the smooth implementation of the New Regulations.
III. Conclusion
Over the past decade, we have been pleased to observe that various QFLP pilot cities have continuously refined their policies based on practical experience and evolving market conditions. The New Regulations serve as an excellent example of this evolution, directly providing greater regulatory support and flexibility on key pain points for foreign investors entering China—such as low entry efficiency, excessive investment restrictions, and inflexible investment structures. We believe that the New Regulations could reshape the QFLP pilot framework and become a national benchmark.