State Administration for Foreign Exchange (SAFE) Shanghai and Zhejiang branches have successively issued implementing rules for the registration of foreign loan signing (modification) for non-financial enterprises with banks (the "Two Regional Rules"), marking the transition of the pilot policy for high-level opening-up of cross-border trade and investment (the "Facilitation Measures") from the pilot phase to regular implementation. The key points of the Two Regional Rules are as follows:

• Non-financial enterprises registered in Shanghai and Zhejiang that borrow foreign loan under the full-caliber cross-border financing macro-prudential mode (the "Full-caliber Mode") based on the entity’s net asset (excluding real estate enterprises, local government financing platforms, financial leasing companies, financing guarantee companies, commercial factoring companies, local asset management companies, small loan companies, and pawnshops) may directly handle foreign loan signing, modification, and cancellation registration at banks; the pilot supporting documents issued by the two regions in early 2024 are simultaneously repealed.
• If foreign-invested enterprises choose to borrow foreign loan under the "total investment minus registered capital" mode, they shall still apply to SAFE for registration procedures in accordance with the Guidelines for Foreign Exchange Business under Capital Account (2024 Edition) (Hui Fa [2024] No. 12).
• Strengthened KYC obligations of handling banks: Banks shall not proceed with foreign loan registration for restricted entities such as real estate enterprises and local government financing platforms, and shall verify whether the debtor's actual situation and application information are consistent with the system information.
• It is clarified that handling banks shall verify the enterprise's remaining quota of cross-border financing in the Capital Account Information System; if the enterprise has objections to the quota query result, the bank shall coordinate with SAFE for review.

The application forms have been updated with unified filling standards; Meanwhile, application materials have been simplified, and written applications are no longer mandatory for foreign loan signing registration, with written explanations only required when necessary.