China's Revised Audit Law Implementation Regulations to Take Effect in December‌

‌In September 2026, the State Council promulgated the new Regulations for the Implementation of the Audit Law of the People's Republic of China, which will come into force officially on December 1, 2026. The 2010 old version of the regulations that has been in use for 16 years will be repealed simultaneously. This revision completes supporting refinement on the basis of the 2021 amendment to the Audit Law, and the core differences between the new and old versions have directly adjusted the compliance boundaries for market entities.

The most core adjustment between the new and old versions is the addition of a political principle in the General Provisions: the old version did not include relevant content in the regulations, while the new version clearly stipulates that audit work must adhere to the leadership of the Communist Party of China, and audit work plans must be submitted for approval in accordance with prescribed procedures, which strengthens the political orientation of audit work at the institutional level.

In terms of audit coverage, the old version only made principled provisions on construction projects mainly invested by the government. The new version directly supplements the details of four categories of "major public engineering projects concerning national interests and public interests", bringing major projects invested by state-owned enterprises and state-owned financial institutions, as well as public resource cooperation projects, all into the audit scope. Meanwhile, the management and utilization of state-owned resources are officially included in the scope of special audit investigations, greatly expanding the coverage breadth.

In terms of behavioral constraints on auditors, the old version had no relevant special systems, while the new version adds a registration and reporting system for inquiries and interference in audit matters. Auditors must register and report in accordance with regulations when encountering such inquiries or interference, so that the independence of audit operations is guaranteed by a clear system.

At the level of rectification responsibilities, the old version only generally mentioned that auditees shall implement audit decisions. The new version clearly divides the subject responsibilities: the auditee bears the primary responsibility for rectification, the competent department bears the supervision responsibility, and the audit authority bears the follow-up review responsibility. It also clarifies the legal consequences of four types of behaviors such as refusing to rectify and prevaricating over rectification, comprehensively upgrading audit rectification from the "soft requirement" in the old version to a "hard constraint".

For enterprises, sorting out internal compliance procedures against the differences between the new and old versions can help them adapt to the regulatory requirements after the implementation of the new regulations in advance.

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