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Internal control systems
in China.

It is fundamental for a business to have efficient and robust internal control systems in place to ensure effective corporate governance. Acclime China’s advisory team takes a hands-on role in helping to establish or strengthen internal controls for your organisation.

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Monitor your goals and objectives.

Expert oversight

We create the mechanisms for you to ensure that assets are safeguarded, financial information is reliable and operations are efficient.

Proactive support

Allow our knowledgeable experts to keep your controls updated when regulatory or business changes impact your existing internal control systems.

Clear communication

Our team believes clear communication and information is paramount to good internal control systems. We adopt a hands-on approach in working with you.
Internal control systems

Our internal control services.

  • Adopting a COSO framework

    The five major components of internal controls according to COSO Framework are control environment, risk assessment, control activities, communication and monitoring. All 17 principles under the five major components are required to be included and function effectively in a company’s internal control structure. The 17 principles consist of the following concepts:

    Control environment

    • Commitment to integrity, ethical values, and behavior of key executives
    • The company maintains appropriate corporate governance and oversight
    • The company creates an appropriate organizational structure and ensures assignment of authority and responsibility
    • Management demonstrates a commitment to competence
    • Accountability is established and enforced

    Risk Assessment

    • Appropriate entity-level objectives have been established and communicated
    • A risk assessment process allowing for the identification and analysis of risk has been established
    • Fraud risk is assessed.
    • Established processes exist to identify and analyze internal and external significant changes which may affect the entity

    Control Activities

    • Control activities are designed and developed 
    • General controls over information technology are designed and developed
    • Policies and procedures set out the control activities


    • Information systems provide management with relevant external and internal information, and that information is provided to the right people
    • Adequate internal communication systems
    • Appropriate external communication systems


    • Periodic evaluations of internal control are made
    • Management analyzes and communicates known deficiencies and responds appropriately to risks related to those deficiencies.
  • Strategies for creating systems upon market entry

    • Systems solutions and implementation – We help you choose the most appropriate financial, HR and accounting solutions to suit your company’s size, needs and budget.
    • Systems and process review – We assist you to review your organisation’s processes from supply chain, Just-in-Time (JIT) manufacturing procedures to re-aligning company structure by process lines. We use a variety of strategies to help achieve excellence.
    • Business process re-engineering – We advise on how to improve efficiencies by streamlining information flows and eliminating inefficient internal processes. By changing and updating current operations, organizations are able to enhance cost competitiveness and further develop market share.

  • Risk management

    Acclime’s advisory experts assess existing financial risks and help implement the most appropriate treasury management strategy in order to face risks head on, while still adapting to your individual business needs.

    In addition, since efficient treasury management also encompasses banking relationships, Acclime can advise foreign companies on how recent reform to the country’s banking system alters the way companies in China should approach their treasury operations.

  • SOX 404 compliance (Sarbanes-Oxley Act)

    In the financial auditing of public companies, SOX 404 top–down risk assessment (“TDRA”) is a financial risk assessment performed to comply with Section 404 of the Sarbanes-Oxley Act of 2002 (SOX 404). This is used to determine the scope and required evidence to support management’s testing of its internal controls as well as by external auditors to issue formal opinions on the company’s internal controls.

    The SOX 404 assessment ensures that all publicly-traded companies establish secure internal controls for financial reporting. They must document, test, and maintain the procedures for the upmost effectiveness of the company. Registered external auditors must attest to the accuracy of the company management’s assertion that internal accounting controls are in place, operational, and effective.

    There are 3 steps to completing the evaluation of the effectiveness of internal controls:

    • Identifying financial reporting risks and the controls that address them
    • Confirming that the controls work in practice
    • Reporting conclusions on overall effectiveness and deficiencies

    Acclime will ensure that your employees understand what they need to do to properly prepare financial reports, and understand the information they need to have them done correctly.

Single time- or project-based fee

Common questions.

What are the auditing requirements in China?

In Western countries limited liability companies are generally subject to an annual audit carried out by independent external auditors whose role is to express an objective opinion on the truthfulness and fairness of the financial statements.

In China, auditing is not a legal requirement but is required under the regulations. Prior to the introduction of the ASBE, the primary objective of auditing in China was to carry out inspection on the financial records of a business to ascertain their accuracy and legality (i.e. whether the transactions conducted complied with relevant state laws and regulations). Auditors in China are concerned with protecting the legal interests of the company as well as the interests of the state. Only with the implementation of the ASBE were the concepts of true and fair presentation introduced.

Prior to 2000 financial statements of state-owned enterprises were not required to be audited annually by independent auditors, but periodical or social audits conducted for the purpose of ascertaining the enterprise’s tax liabilities or other purposes might be conducted by the State Audit Bureau or Tax Bureau. Since 2002, except for a few types of specialised industries that have been explicitly exempted, all other state-owned enterprises must be audited at least annually. In addition, the regulations governing the accounting of joint stock companies and foreign investment enterprises require these companies to be subject to annual audit carried out by a registered Chinese certified public accounting firms. When reporting on whether the financial statements of foreign investment enterprises are prepared in accordance with the relevant laws and regulations, auditors may make reference to the following main laws and regulations:

  • The PRC Sino-foreign Equity Joint Venture Law (EJV Law) promulgated by the National People Congress (NPC), effective July 8, 1979 and revised March 15, 2001
  • Implementing Regulations of the EJV Law promulgated by the State Council (SC), effective September 20, 1983 and revised July 22, 2001
  • The PRC Sino-foreign Cooperative Joint Venture Law (CJV Law) promulgated by the NPC, effective April 13, 1988 and revised October 31, 2000
  • The PRC Wholly Foreign-Owned Enterprise Law (WFOE Law) promulgated by NPC, effective April 12, 1986 and revised October 31, 2000
  • Implementing Rules of the WFOE Law promulgated by SC, effective December 12, 1990 and revised April 12, 2001
  • The PRC Small and Medium Enterprises Law (SME Law) promulgated by NPC and effective June 29, 2002 and revised October 18, 2011
  • Regulation on the implementation of Enterprise Income Tax Law of the PRC promulgated by NPC and effective January 1, 2008
What is the Accounting Law in China?
First promulgated in 1985, the Accounting Law was revised in December 1993 and then in 1999. From July 1, 2000, the new accounting law was adopted. It represents the highest level of legal norms governing accounting and forms the basis for the formulation of administrative rules and regulations in regard to accounting, as well as providing the highest guiding principles on accounting work. In tandem with this piece of specialised legislation, a number of corresponding laws were passed in the 1990s, including the Certified Public Accountant Law, Budget Law and Audit Law followed by related legislation such as Company Law, Law on Negotiable Instruments, Enterprise Bankruptcy Law, Economic Contract Law, and various tax laws. Together they constitute a legal framework of related economic legislation, forming the cornerstone of a legal system governing accounting work.
What is the relationship between the Accounting Standards and the Accounting System?

Both the Accounting system and Accounting standards constitute an integral part of China’s unified accounting system. As administrative documents, they set out the rules for accounting such as the recognition, measurement, disclosure and reporting of accounting elements. While both are formulated and promulgated by the MOF, certain differences exist between the two.

Firstly, in terms of the scope of application, specific accounting standards are mostly applicable to joint stock limited companies although some of them also apply to other enterprises. As for the Accounting System, apart from joint stock limited companies, other qualified enterprises may also adopt the system but prior approval is required for state-owned enterprises wishing to implement the system.

Secondly, the Accounting System covers all aspects of an enterprise’s transactions and events. In other words, if an enterprise falls within the scope of the Accounting System, the accounting treatment of all its transactions and events must be handled according to the stipulations of the system. As for specific accounting standards, they only govern certain transactions and events or certain accounting aspects of an enterprise. For instance, all the 13 specific accounting standards issued to date merely deal with specific transactions and events of an enterprise.

Thirdly, stipulations concerning the recognition, measurement, disclosure and reporting of accounting elements contained in the specific accounting standards are more general, with no stipulations on how accounting records should be made. By comparison, stipulations in the Accounting System are more specific, giving detailed rules on the account titles and instructions for use.

What are the issues involved in the implementation of a new accounting system?

Since 1 January 2002, FIEs have implemented the Accounting System for Business Enterprises promulgated by the MOF on 29 December 2000, while the Accounting System for Foreign-invested Enterprises issued by the MOF on 24 June 1992 and its related regulations on account titles and financial statements were nullified. Below are certain issues concerning the implementation of the new accounting system.

If an FIE has to change its accounting estimate as a result of implementing the accounting system, all changes should be made using the prospective application. If an FIE has to change its accounting policies, the following circumstances where it is stipulated that the retrospective adjustment method is to be used:

  • Provision for short-term investment write-down and provision for impairment of long-term investment, fixed assets, intangible assets, construction in progress and designated loans.
  • The difference between provision for bad debts on receivables and provision for inventory write-down under the new accounting system and those under the old system.
  • The changes in depreciation life and residual value for the first time, should be treated as change in accounting policy in the current year and adopt retrospective adjustment method. After that, if FIE adjust on depreciation life and residual value again, it should adopt prospective method.
  • Investments made before the accounting system was implemented and which continue after the implementation date should be treated according to the stipulations of the Accounting System as from the date of implementation. In other words, investments and investment income confirmed under the old system prior to the implementation of the new accounting system may not be adjusted retrospectively. Any subsequent confirmation of investment income and adjustment of the book value of investments should be treated according to the stipulations of the Accounting System.
  • In implementing the accounting system, under the new accounting standards that promulgate in 2006, the set-up cost cannot be amortised anymore. Instead, the set-up costs should be entered directly under G&A expenses during the set-up period. 

FIEs should abide by the following stipulations in implementing the accounting system:

  • The balance of “marketable securities” should be entered under “short-term investment”.
  • The balance of “advance payment for goods” and the balance of “advance receipt of payment for goods” should be entered under “prepayment” and “receipt in advance” respectively.
  • The balance of “provision for loss in inventory realisation” should be entered under “provision for inventory write-down”.
  • The creditor’s balance of “exchange loss during set-up period” should be entered into the profit and loss account of the current period.
  • The balance of other deferred expenses should be treated according to different circumstances: it should be entered under “long-term prepaid expenses” if it can generate benefits in subsequent accounting periods; it should be entered under the profit and loss account of the current period if it cannot generate benefits in subsequent accounting periods.
  • The balance of “deferred investment loss” should be treated according to different circumstances: it should be entered under “long-term prepaid expenses” if it is a debitor’s balance; it should be entered under “deferred income” if it is a creditor’s balance.
  • The balance of bonds payable and the premium or discount on bonds payable should be entered under “bonds payable”.
  • The balance of “wages payable” (or “wages and welfare expenses payable”) should be entered under “payroll payable to the employees (including wages, bonuses and allowances, employee incentive and welfare funds drawn from the enterprise’s after-tax profits); the welfare expenses comes under pension funds, insurance, welfare funds and different kinds of subsidies payable to mainland workers should be entered under profit and loss account of the corresponding period when it actually occurred.
  • The balance of “reserve fund”, “enterprise development fund” and “profit capitalised on return for investment” should be entered under “surplus reserve”.
  • A new item, “deferred income”, should be created under “estimated liabilities” on the balance sheet.
  • A new item, “of which: investment of Chinese party (balance of non-renminbi capital at end of period)” and investment of foreign party (amount of non-renminbi capital at end of period)”, should be created under “paid-in capital” on the balance sheet.
  • Foreign-invested tourism enterprises, in implementing the Accounting System, should for the time being follow the regulations in the Account Titles and Financial Statements for Foreign-invested Tourism Enterprises in compiling their income statements and supporting reports.

When compiling comparative financial statements using the retrospective adjustment method, if changes in accounting policies occur during the periods covered, adjustments should be made to the net profits and losses and other related items in the periods concerned accordingly. For entries in comparative financial statements subject to cumulative effect due to policy change prior to the periods covered, adjustments should be made to the initial retained income as well as other related items.

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