On September 14, 2026, the Notice on Matters Concerning Cross-Border RMB and Foreign Currency Cash Pooling by Multinational Companies, jointly issued by the People's Bank of China (PBOC) and the State Administration of Foreign Exchange (SAFE), officially took effect. The following day, Global Consumer Boutique (Hainan) Trading Co., Ltd. completed a cross-border fund transfer in Haikou through the Bank of China's Hainan Branch, becoming one of the first multinational companies in Hainan to transact under the new rules.

This arrangement is commonly called "cross-border cash pooling." Put simply, regulators set an overall quota for cross-border fund transfers for multinational companies that meet eligibility requirements. Within that quota, companies can move funds between domestic and overseas affiliates at their discretion.

In fact, this model has been operating in China for more than a decade. Pilot programs for the centralized management of multinational companies' foreign exchange funds began in 2012. In 2019, SAFE issued the Provisions on the Centralized Operation and Management of Cross-Border Funds of Multinational Companies, replacing the 2015 rules. In 2021, the PBOC launched pilot programs for integrated RMB and foreign currency cash pooling. In 2025, the PBOC and SAFE cash pooling schemes were consolidated.

"The cash pooling rules that officially took effect on September 14, 2026, are also known as the new cash pooling policy. Previously, there were four cash pooling schemes, each with different coefficients for fund inflows and outflows — 0.3, 0.8, or 1 — and for external debt, 2.0 or 3.5. This made the rules difficult for banks and companies to navigate," said Fang Jiehong, deputy head of the Cross-Border RMB & FX and Clearing Team at Bank of China Hainan Branch.

Compared with the previous version, the new cash pooling rules introduce several changes. The most notable concern is quotas: the coefficient for overseas lending, calculated against owners' equity, has been raised from 0.3 to 0.6, while the coefficient for external debt has been raised from 2 to 3.5. These changes significantly expand companies' capacity for cross-border borrowing and lending. Eligibility requirements have also been eased: companies can now qualify based on either their balance-of-payments volume or operating revenue, with the thresholds halved for companies based in pilot free trade zones. Administration is more flexible, too: companies can set their own fund-pooling ratios and adjust them once a year, and the scheme now operates under a filing-based system.

Global Consumer Boutique (Hainan) Trading Co., Ltd. is a multinational company specializing in duty-free wholesale and retail. It operates duty-free stores in Hainan and sources products from brands worldwide through two Hong Kong subsidiaries for its cross-border e-commerce business.

The Hong Kong subsidiaries pay brands in US dollars, as does the company’s overseas e-commerce business when it receives payments. However, shoppers at its domestic duty-free stores pay in CNY, creating an inherent currency mismatch in the business model, said the company's chief financial officer, Yang Yan.

The mismatch goes beyond currencies to payment timing. Some brands require payment before delivery, while inventory for peak seasons, such as China’s Double 11 shopping festival and the Spring Festival holiday, must be built up in September or October. The gap between purchasing and sales also exposes the company to exchange-rate risk.

In 2023, Global Consumer Boutique established a cross-border cash pool with Bank of China. "Previously, a single cross-border transfer could take anywhere from ten days to a full month," stated Yang. Now, with the cash pool, a cashier can simply move funds between the company's internal accounts. The process requires only two levels of approval within a given enterprise, the finance department manager and the CFO, and can be completed entirely through online banking. Yang describes the change as "a qualitative leap."

The transfer completed on September 15 used the higher quota available under the new cash pooling rules, meeting the Hong Kong subsidiary's funding needs for Double 11 procurement and inventory buildup. Transferring funds to the Hong Kong subsidiaries through the pool is both faster and cheaper. For companies that had already set up cash pools, switching from the previous version to the new one was seamless.

The company's cross-border e-commerce business in Hong Kong has grown rapidly over the past two years, Yang said, making its two Hong Kong subsidiaries central to the company's future strategy. An integrated RMB and foreign currency cash pool helps multinationals coordinate fund management by directing their idle funds where they are needed, while reducing overall funding costs and improving returns on capital.

"With the quotas now relaxed, they better align with the growth of our Hong Kong subsidiaries. Combined with the FTP's tax policies, these changes help multinationals like us plan our global strategies and operations more effectively," Yang added.

Executive Presenter: Shang Lin

Chief Producer: Niu Xiaomin

Creative Producer: Zhou Yuan

Producers: Chen Shuhuan, Wang Jingxuan

Production Coordination / Video Scripts: Chen Xiaodan

Video Editor: Zhou Chenguang

Camera Operator: Wu Duosheng

Visual Effects: Yan Lechi

English Proofreader: David Janke

Graphic Design: Liang Yuzheng, Shang Yingxi

Voiceover: Iain Inglis (UK)

Writer: Chen Xiaodan