Cross-border banking · Shanghai

NRA & FTN accounts.
A China bank account without a China company.

Q: What is the difference between an NRA account and an FTN account?

They sit under different rulebooks. An NRA account follows the nationwide non-resident account rules — SAFE's 2009 circular for foreign currency, and the PBOC's 2010 and 2012 rules for RMB — which means your foreign currency and your RMB live in two separate accounts governed separately. An FTN account is the non-resident member of the Free Trade account system built for the Shanghai Free Trade Zone, where RMB and foreign currency sit in one unified account framework operated through a bank's ring-fenced separate accounting unit. FTN is only available at banks that run such a unit. In short: NRA is available more widely; FTN is more integrated but tied to the free trade zone framework and to a smaller set of banks.

Q: Can I move money from an NRA account to a normal Chinese company's account?

Yes, but it is treated as a cross-border transaction, not a domestic transfer. The domestic party's bank reviews the underlying commercial documents in the same way it would for a payment arriving from overseas. Practically, this means every movement into the domestic system needs a real, documented commercial reason. Transfers in the other direction — out to overseas accounts, to other non-resident accounts, or to an offshore account — can generally be executed by your bank on your instruction.

Q: How is an NRA account different from an offshore (OSA) account or a Hong Kong account?

An OSA is held at the offshore banking department of a mainland bank that holds a specific offshore banking licence, under rules dating from 1997. The NRA rules expressly exclude offshore accounts from their scope — it is a genuinely separate regime, offered by far fewer banks. A Hong Kong account sits entirely outside mainland regulation. It is more flexible, but every payment to or from China is a real cross-border transfer, and it gives you no presence inside the mainland settlement system. Many of our clients end up holding both a Hong Kong account and an NRA account, using each for what it is good at.

Q: Is any of this changing?

Yes, in two places worth watching. SAFE issued a draft Regulation on Bank Corporate Foreign Exchange Accounts for public comment in May 2026, which would fold foreign-currency NRA accounts into a single unified corporate FX account framework and replace the 2009 circular. Separately, the PBOC's Shanghai head office launched a free trade account function-upgrade pilot in December 2025, which as at mid-2026 covered a small number of banks and qualifying zone-registered enterprises. Neither changes what you can do today, and we would not plan a structure around a consultation draft. We track both and will tell you if something lands that affects your account.

An overseas company can hold a bank account inside mainland China without registering a local entity. Two frameworks make that possible: the NRA account (non-resident account, 境外机构境内账户) and the FTN account (free trade non-resident account, 境外机构自由贸易账户). They are not the same thing, and picking the wrong one wastes months.

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A China bank account for a foreign company
Works for offshore companies — HK, Singapore, BVI
No WFOE or local entity required
English-speaking, one point of contact

The basics

What an NRA account and an FTN account actually are

Both are accounts held inside mainland China by a company registered outside it — including Hong Kong, Macau and Taiwan entities. The difference is which rulebook the account sits under, and what that rulebook lets you do.

NRA

Non-Resident Account

境外机构境内账户 — the nationwide framework.

An NRA account is opened by an overseas entity at a bank inside mainland China. The account number carries the prefix “NRA” so that any counterparty and their bank can tell immediately that it belongs to a non-resident.

There are in practice two separate NRA regimes, each with its own rules:

Foreign-currency NRA — under SAFE Circular Huifa [2009] No. 29
RMB NRA — under PBOC Yinfa [2010] No. 249 and [2012] No. 183

Available: at qualified banks across mainland China

FTN

Free Trade Non-Resident Account

境外机构自由贸易账户 — the free trade zone framework.

An FTN account is the non-resident member of China’s Free Trade (FT) account system, created for the Shanghai Free Trade Zone and operated through a bank’s ring-fenced separate accounting unit (分账核算单元).

The FT family is split by who holds the account:

FTE — enterprises inside the zone
FTN — overseas institutions (this one)
FTU — financial institutions
FTI / FTF — individuals in the zone

Available: at banks with a qualified FT accounting unit

Why bother

Why an overseas company needs an account inside China.

Most foreign companies trading with China start by invoicing from abroad and collecting into a Hong Kong or home-country account. That works — until it doesn't. An in-China non-resident account solves a specific set of problems that an offshore account cannot.

It is also a genuine alternative to incorporating. If you don't yet need a Chinese legal entity, staff, or the ability to issue fapiao, an NRA or FTN account gives you a China-side settlement point without the ongoing cost of WFOE registration and monthly accounting.

Your Chinese counterparties prefer it. Payments settle domestically to a mainland bank rather than through a correspondent chain, which removes a common source of delay and of “the payment is stuck in compliance” conversations.
You can hold and settle in RMB. A RMB NRA account lets an overseas entity receive and pay cross-border RMB under the current-account and permitted capital-account rules, without converting through a third currency.
It supports the trade you already do. Goods trade, services, entrepot and offshore trading structures all become easier to document and settle when one leg of the flow sits at a mainland bank.
No local entity, no local payroll. The account belongs to your overseas company. There is no Chinese subsidiary to register, audit, staff or eventually deregister.
Visible, reportable, defensible. NRA and FT accounts are formal regulated frameworks reported to SAFE and the PBOC — not a workaround. That matters when your bank, your auditor or your counterparty asks how the money moves.

The key decision

NRA vs FTN: the core differences

This is the question that decides everything else — which bank you approach, what you can do with the balance, and how the money crosses back into the domestic system. Below is how the two frameworks are set up in principle; your bank's own policy sits on top of all of it.

Comparison of NRA accounts and FTN free trade accounts in China
	NRA account	FTN account
Regulatory basis	SAFE Huifa [2009] No. 29 for foreign currency; PBOC Yinfa [2010] No. 249 and Yinfa [2012] No. 183 for RMB	PBOC Yinfa [2013] No. 244 on financial support for the Shanghai FTZ, implemented through the PBOC Shanghai separate-accounting rules issued in May 2014
Currency structure	Foreign currency and RMB sit in two different accounts under two different rulebooks	A single account framework covering RMB and foreign currency under one set of rules
Where you can open it	Qualified banks across mainland China	Only banks that operate a qualified separate accounting unit; launched in Shanghai and since replicated in other free trade zones
Converting FX into RMB	An FX NRA account may not, in principle, be converted into RMB without approval from the local SAFE branch	Conversion follows the FT account rules, under which funds relating to business already made convertible may be exchanged — subject to the bank’s own review
Cash	No foreign-currency cash deposits or withdrawals without approval; RMB NRA accounts are not for cash business either	Handled inside the FT framework; treat cash as unavailable in practice
Moving money offshore or to another non-resident account	Transfers abroad, between NRA accounts, or to an offshore (OSA) account can generally be executed by the bank on your instruction	Flows to and from overseas accounts — the so-called “first line” — are the part the system is designed to keep open
Moving money to a domestic Chinese account	Treated as a cross-border transaction; the domestic side’s bank reviews the underlying trade documents	The “second line” — limited penetration and strict management, also handled as cross-border business
Effect on the bank	FX NRA balances feed into the bank’s cross-border debt / external debt metrics, which is why some banks ration them	Managed on a macro-prudential basis within the accounting unit
Best suited to	Straightforward trade settlement and RMB collection by an overseas company, anywhere in China	Overseas entities working with Shanghai FTZ counterparties, or in structures where a unified RMB/FX account is the point

NRA vs offshore account, Hong Kong account, and a Chinese entity

Option	Who holds it	What it is
NRA / FTN	Your overseas company	A non-resident account at a mainland bank, inside the Chinese regulatory perimeter and reported to SAFE / the PBOC.
Ordinary company account	A Chinese entity you own (e.g. a WFOE)	A resident account. Full domestic capability — fapiao, payroll, domestic settlement — but you must first register, capitalise, audit and maintain the entity.
OSA (offshore account)	Your overseas company	Held at the offshore banking department of a mainland bank licensed for offshore business, under the 1997 offshore banking rules. Expressly outside the NRA regime — a different licence, a much smaller set of banks.
Hong Kong bank account	Your overseas company	Entirely outside mainland regulation. Flexible, but every payment to and from China is a genuine cross-border transfer, and account opening standards for small entities have tightened considerably.

Still not sure which account you need?

Tell us who pays whom, in what currency, and we’ll tell you whether it’s NRA, FTN, or neither. First conversation is free.

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Fit check

Who these accounts are for

NRA and FTN accounts are a good answer to a narrow set of problems. If you recognise your business below, the conversation is worth having.

Exporters selling into China

You invoice Chinese buyers from abroad and want collection to land at a mainland bank instead of running through a correspondent chain your customer’s finance team doesn’t understand.

Importers buying from China

You pay a portfolio of Chinese suppliers and want a settlement point on the China side — particularly if suppliers are asking to be paid in RMB.

Hong Kong & offshore trading companies

An offshore company — HK, Singapore, BVI — sitting between a Chinese factory and an overseas buyer, needing a China bank account for a clean, documented China-side leg.

Groups with a China supply chain but no entity

You buy, QC and ship from China but have deliberately not incorporated there, and don’t want to start now just to hold a bank account.

Companies testing the market first

You expect to register a WFOE eventually, but want to trade and settle for a year or two before committing to an entity and its running costs.

Overseas parents of an existing China business

Your group already has a Chinese subsidiary, and the overseas parent needs its own China-side account for flows that don’t belong on the subsidiary’s books.

Where these accounts are not the answer

A non-resident account does not make your overseas company a Chinese company. It will not let you issue fapiao, employ staff on PRC contracts, hold a business licence, or trade domestically as a Chinese seller. If you need any of those, you need an entity — see WFOE registration, accounting and tax in Shanghai on our services page, or the WFOE / JV / Rep Office FAQ if you're still weighing structures.

Main advantages

What you actually gain.

Stripped of the marketing, here is what an NRA or FTN account changes about how your company deals with China — and, just as usefully, what it doesn’t.

We’d rather you understood the limits before you spend three months on an application. Most of the disappointment we see comes from expectations set by someone who was paid to open the account, not to make it useful.

No entity, no entity costs. No registered capital, and none of the annual audit, AMR filing and monthly bookkeeping a Chinese company carries — nor the deregistration headache years later.
A domestic settlement point. Your Chinese counterparty pays a mainland bank account, which is operationally simpler for them and quicker to reconcile for you.
Cross-border RMB, properly. Receive and pay RMB across the border within the permitted current-account and capital-account scope, and hold the balance in the account.
Free movement offshore. Transfers out to overseas accounts, to other non-resident accounts and to offshore accounts can generally be run on your instruction.
A named regulatory framework. When a bank compliance officer, an auditor or a counterparty asks what the account is, there is a circular number to point at.
An honest set of limits. Conversion is restricted, cash is effectively off the table, and every movement to a domestic account is reviewed as a cross-border transaction. Plan around it rather than discovering it.

How it works

NRA account opening: how the process runs

Every bank runs this slightly differently, and the sequence below is the shape of the work rather than a fixed schedule. The step that decides the timeline is almost always the bank’s own review — not the paperwork.

1

Scope the account

We establish what the money is actually doing: which currencies, which counterparties, which direction, and whether the underlying business is current-account trade or something on the capital side. This determines whether NRA, FTN, or neither is the right answer.
2

Match you to a bank

Banks differ enormously in appetite for non-resident accounts — by your jurisdiction, your industry, your expected volumes and their own internal quota. We approach banks we know are currently open to a profile like yours, rather than applying blind.
3

Prepare and legalise documents

Corporate documents from outside mainland China generally need to be produced as originals, and non-Chinese documents need a Chinese translation. Depending on your jurisdiction and the bank, notarisation and consular legalisation or apostille may also be required. This is the part clients underestimate.
4

Bank review and KYC

The bank verifies your company’s existence and standing, identifies your legal representative or authorised signatory and the beneficial owners, and satisfies itself about the commercial rationale under its anti-money-laundering obligations. Expect questions about specific contracts and counterparties.
5

Registration and codes

Where required, the bank obtains a special institution code for your overseas entity and registers its basic information with the regulator, so the account can be reported through the official account information systems. The account number is issued with the NRA or FT prefix.
6

Activation and first flows

We walk your finance team through what the account can and cannot do, how to describe payments so they clear cleanly, and what documentation your counterparties’ banks will ask for on the domestic side.

Paperwork

Documents typically required

The list below reflects what the account rules require and what banks routinely ask for on top. Your bank will issue its own definitive checklist, and it will be longer than the regulatory minimum — that is normal.

Company documents

Certificate of incorporation / registration, showing your company is lawfully established outside mainland China
Certificate of incumbency or equivalent good-standing evidence
Articles of association or company constitution
Register of directors and shareholders / beneficial ownership chart
Business licence or regulatory approval, where your activity requires one

Note: originals are generally expected

People

Passport of the legal representative or person in charge
Where no legal representative signs, the passport of the authorised signatory named in the company constitution, plus the constitution itself
Board resolution or power of attorney authorising the account opening
Identification for anyone attending the bank on your behalf
Beneficial owner identification for AML purposes

Note: some banks require an in-person visit

Translation & legalisation

Chinese translation of every non-Chinese document
Translations stamped or signed as the bank requires
Notarisation and consular legalisation or apostille, depending on jurisdiction and bank policy
The account name must match the company name on your registration documents exactly

Note: the slowest step in most cases

Commercial background

Explanation of the intended use of the account and expected flows
Sample contracts, purchase orders or invoices with Chinese counterparties
Company profile, website, and description of the group structure
Existing banking relationships and reference letters, if requested
Special institution code, where one has already been issued to your entity

Note: the real deciding factor at KYC

Questions we get every week

NRA & FTN account FAQ

Can my overseas company open a China bank account without registering a Chinese company?

Yes. That is exactly what the NRA framework exists for. A company lawfully registered outside mainland China — including in Hong Kong, Macau or Taiwan — can open an account at a mainland bank, and the account carries the “NRA” prefix so everyone in the payment chain can see it belongs to a non-resident. You do not need a WFOE, a licence or a local address to hold one. What you do need is a bank willing to take you on.

What is the difference between an NRA account and an FTN account?

They sit under different rulebooks. An NRA account follows the nationwide non-resident account rules — SAFE’s 2009 circular for foreign currency, and the PBOC’s 2010 and 2012 rules for RMB — which means your foreign currency and your RMB live in two separate accounts governed separately.

An FTN account is the non-resident member of the Free Trade account system built for the Shanghai Free Trade Zone, where RMB and foreign currency sit in one unified account framework operated through a bank’s ring-fenced separate accounting unit. FTN is only available at banks that run such a unit.

In short: NRA is available more widely; FTN is more integrated but tied to the free trade zone framework and to a smaller set of banks.

Can I convert foreign currency in an NRA account into RMB?

As a rule, no. Under the foreign-currency NRA rules, funds in the account may not be converted into RMB — directly or indirectly — without approval from the local SAFE branch, and foreign currency cash cannot be deposited or withdrawn either.

This is the single most common surprise for new account holders, and it is worth designing your flows around rather than fighting. Note also that SAFE published a draft consolidated corporate foreign exchange account regulation in May 2026 which, among other things, sets out express exceptions where conversion would be permitted. It was still a consultation draft at the time of writing, so treat anything you read about it as forthcoming rather than current.

Can I move money from an NRA account to a normal Chinese company's account?

Yes, but it is treated as a cross-border transaction, not a domestic transfer. The domestic party’s bank reviews the underlying commercial documents in the same way it would for a payment arriving from overseas.

Practically, this means every movement into the domestic system needs a real, documented commercial reason. Transfers in the other direction — out to overseas accounts, to other non-resident accounts, or to an offshore account — can generally be executed by your bank on your instruction.

How is an NRA account different from an offshore (OSA) account or a Hong Kong account?

An OSA is held at the offshore banking department of a mainland bank that holds a specific offshore banking licence, under rules dating from 1997. The NRA rules expressly exclude offshore accounts from their scope — it is a genuinely separate regime, offered by far fewer banks.

A Hong Kong account sits entirely outside mainland regulation. It is more flexible, but every payment to or from China is a real cross-border transfer, and it gives you no presence inside the mainland settlement system. Many of our clients end up holding both a Hong Kong account and an NRA account, using each for what it is good at.

How long does it take, and what does it cost?

We deliberately don’t publish a number for either. Timelines are driven by the bank’s internal review and by how long legalisation takes in your jurisdiction, both of which vary by more than any average would usefully capture. Anyone quoting you a guaranteed number of working days for a non-resident account is guessing.

What we will do is give you a specific, honest estimate once we know your jurisdiction, your business, and which bank we are approaching — along with a fixed quote for our own fee before any work starts.

Do I need to travel to China to open the account?

It depends on the bank. Some will complete the process on documents alone with a properly executed power of attorney; others insist on meeting the legal representative or authorised signatory in person. We confirm this before you commit to a bank, so that if a trip is needed you can plan one visit rather than three.

Can I hold RMB in the account and use it to pay Chinese suppliers?

Yes — that is one of the main uses of an RMB NRA account. The permitted income and expenditure scope covers cross-border settlement of goods trade, services, income and current transfers, capital-account items that policy expressly permits or that have been approved, cross-border RMB trade finance, interest earned on the account, and transfers from other non-resident RMB accounts.

Your bank reviews the authenticity of each receipt and payment against the underlying business, so keep your contracts and invoices in order.

Why do some banks refuse to open an NRA account for us?

Usually one of three reasons. First, appetite: non-resident accounts carry heavier compliance obligations, and some branches simply aren’t taking new ones. Second, your profile: certain jurisdictions, industries and ownership structures trigger enhanced due diligence that a given bank would rather avoid. Third, balance-sheet treatment — foreign-currency NRA balances feed into the bank’s cross-border debt metrics, so capacity can be genuinely limited.

A refusal from one bank says very little about your prospects at another. The work is in knowing which door to knock on.

Is any of this changing?

Yes, in two places worth watching. SAFE issued a draft Regulation on Bank Corporate Foreign Exchange Accounts for public comment in May 2026, which would fold foreign-currency NRA accounts into a single unified corporate FX account framework and replace the 2009 circular. Separately, the PBOC’s Shanghai head office launched a free trade account function-upgrade pilot in December 2025, which as at mid-2026 covered a small number of banks and qualifying zone-registered enterprises.

Neither changes what you can do today, and we would not plan a structure around a consultation draft. We track both and will tell you if something lands that affects your account.

Get in touch

Tell us what the money needs to do.

Describe the flows — who pays whom, in what currency, for what — and we’ll tell you whether an NRA account, an FTN account, or a Chinese entity is the right answer. If it’s none of the three, we’ll say that too. The first conversation is free and we reply within one business day.

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Important notice

The information on this page is provided for general reference only and is a plain-language summary of publicly available regulations. It is not legal, tax or financial advice, and no client relationship arises from reading it. Cross-border account rules in China change, and individual banks apply their own eligibility criteria, documentation requirements and internal policies on top of the regulations. The current requirements of the relevant regulators — the People’s Bank of China and the State Administration of Foreign Exchange — and of the account-opening bank always prevail. Please obtain advice on your specific circumstances before acting.

Principal sources: SAFE Circular Huifa [2009] No. 29 on foreign exchange accounts of overseas institutions in China; SAFE’s catalogue of regulations in force as at 30 June 2026; the SAFE draft Regulation on Bank Corporate Foreign Exchange Accounts released for comment on 22 May 2026; PBOC Yinfa [2010] No. 249 Measures for RMB Bank Settlement Accounts of Overseas Institutions; PBOC Yinfa [2012] No. 183; PBOC Shanghai head office materials on the Shanghai FTZ separate-accounting rules (May 2014) and Yinzongbufa [2025] No. 96 on the free trade account function upgrade.