In accordance with The Administrative Measures for the Qualifications of Accounting Practitioners (“Order No. 73”) and the Provisions on Transition between the Previous and New Administrative Measures on Accounting Qualification (the “Provisions”), Shanghai Municipal Finance Bureau has issued the Implementing Measures of Shanghai Municipality for the Administration of Accounting Practitioner's Qualifications (the “Implementing Measures”), which went into effect as of July 1, 2013. At the same time, Shanghai Municipal Finance Bureau also issued a Notice of Promulgating the “Circular on Printing and Distributing the Provisions on Transition between the Previous and New Administrative Measures on Accounting Qualification” (the “Notice”). Here are some FAQs:

Q1: What are the amendments the Implementing Measures have made?

A: The Implementing Measures consist of 5 chapters with a total of 34 articles. There are 10 major amendments. 1. The policy to allow exemption from APQE subjects has been annulled. 2. It is made clear that applications should take and pass all three subjects of the exam at one time (within the same month). 3. The procedure for claiming AQC has been simplified. 4. It is no longer necessary to register for AQC. 5. A credit-based management system has been adopted for continuing education. 6. The procedure for any AQC holder to modify their information has been simplified. 7. In the case of AQC loss, the requirement has been made clear for the AQC holder to make a public announcement about the loss and apply for a new AQC. 8. AQC should be renewed every 6 years. 9. A new provision has been adopted for the people who are practicing as accountants but have not obtained AQC for various reasons to apply for AQC. 10. Regulations on the legal liabilities of AQC holders have been made clear and complete.

Q2: What are the requirements for any APQE taker?

A: Any applicant who signs up for APQE shall meet the requirements under Article 7 of the Implementing Measures. The applicant should also have formal employment or residence permit in Shanghai.

Q3: Is the former policy allowing exemption from examination still effective after the Implementing Measures take effect?

A: The former policy allowing exemption from examination shall be annulled by the Implementing Measures. Applicants should sign up to take three subjects at one time and shall pass all three subjects within one month. The qualifying result of any subject does not count where the applicant fails one or both of the other two subjects.

Q4: How can applicants sign up for APQE?

A: APQE is computer-based in Shanghai and shall be taken on a monthly basis. The applicant shall sign up and pay online. The applicant shall take the exam the following month after the application is filed and accepted. The principle shall be “first come first served”, and later signers shall take the exam only if there is still quota. The applicant shall order books online and the books shall be delivered by a courier. Within a calendar year, each applicant shall only sign up twice at most, and each time he shall sign up to take all three subjects.

Specific exam rules shall be formulated in accordance with relevant regulations made by the Ministry of Finance.

Q5: Article 10 of the Implementing Measures states that applicants shall sign up for all the three APQE subjects and pass them within one month; the qualifying result of any single subject shall become invalid where the applicant has failed any other subject or both of the two other subjects. How can we understand that?

A: It means that any applicant shall sign up for all three subjects of the accounting practitioner qualification exam and pass all the three subjects within the same month. Where the applicant fails to pass any single subject, the qualifying result of any subject or all subjects shall become invalid. The applicant shall sign up for the exam again and must sign up for all the three subjects at the same time.

Q6: How can we understand the term: “qualifying result of any subject” in the Notice?

A: The case may be that:

1. any applicant passes the exam of Finance and Economic Laws and Regulations and Accounting Professional Ethics, and Accounting Fundamentals within the same calendar year after January 1, 2011; or

2. any applicant passes the exam of Primary Computer-aided Accounting Computation conducted by Shanghai Municipal Finance Bureau before July 1, 2013 .

Q7: How can we correctly understand the transition policy regarding the validity of qualifying result of any subject?

A: Applicants who have obtained any qualifying result of any test subject before July 1, 2013, are eligible to apply for taking the failed subjects under the previous Administrative Measures on Accounting Qualification before the new Implementing Measures enter into effect.

Applicants who have obtained any qualifying result of any test subject before July 1, 2013, are eligible to take the exam of the failed subjects only once before December 31, 2014 after the Implementing Measures enter into effect. The timeline for signing up is as follows:

1. For applicants who have passed the exam of Primary Computer-aided Accounting Computation conducted by Shanghai Municipal Finance Bureau before July 1, 2013:

a. If they have taken the exam of both Finance and Economic Laws and Regulations and Accounting Professional Ethics, and Accounting Fundamentals once between January 1, 2013 and June 30, 2013, they are eligible to take the exam of the failed subjects once before December 31, 2013;

b. If they have taken the exam of both Finance and Economic Laws and Regulations and Accounting Professional Ethics, and Accounting Fundamentals twice between January 1, 2013 and June 30, 2013, and still fail to pass both or one of the subjects, they are eligible to take the exam of the failed subject or subjects at one time in 2014 and they may sign up only once.

2. For applicants who haven’t passed the exam of Primary Computer-aided Accounting Computation conducted by Shanghai Municipal Finance Bureau before July 1, 2013:

a. If they have passed the exam of Finance and Economic Laws and Regulations and Accounting Professional Ethics, and Accounting Fundamentals in 2011, or if they have taken the exam of Finance and Economic Laws and Regulations and Accounting Professional Ethics, or Accounting Fundamentals once between January 1, 2013 and June 30, 2013, and have passed one of them, they are eligible to take the exam of the failed subject or subjects once before December 31, 2013.

b. If they have taken and passed the exam of Finance and Economic Laws and Regulations and Accounting Professional Ethics, and Accounting Fundamentals in 2012 or between January 1, 2013 and June 30, 2013, they are eligible to take the failed subject once before December 31, 2014.

Q8: Some applicants have taken the exam of Finance and Economic Laws and Regulations and Accounting Professional Ethics, and Accounting Fundamentals twice from January 1, 2013 to June 30, 2013, and have passed one subject, but they have not taken or passed the exam of Primary Computer-aided Accounting Computation conducted by Shanghai Municipal Finance Bureau. After the Implementing Measures enter into effect on July 1, 2013, are they eligible to take exam of the failed subjects before December 31, 2014.

A: If applicants have not taken or passed the exam of Primary Computer-aided Accounting Computation conducted by Shanghai Municipal Finance Bureau before July 1, 2013, and have taken the exam of Finance and Economic Laws and Regulations and Accounting Professional Ethics, and Accounting Fundamentals twice between January 1, 2013 and June 30, 2013 and have passed one subject, they are not eligible for the Transitional Policy concerning the validity of qualifying result of any subject, and therefore they are not eligible to take the exam of the failed subjects before December 31, 2014. Instead, they should sign up to all three subjects at one time, and pass all the subjects within the same month according to Article 9 of the Implementing Measures.

Q9: When shall the qualifying applicants under Article 10 of the Implementing Measures claim their AQC after the Implementing Measures enter into effect?

A: After the Implementing Measures enter into effect, the applicants who have taken all three subjects at once and passed them within the same month shall claim their AQC at the address designated by the administrative organ within six months after the result is announced.

Q10: Some applicants have passed the APQE conducted by the Shanghai municipal authority by July 1, 2013, but have not claimed their AQC. When shall they claim their AQC after July 1?

A: All applicants who have taken the APQE in Shanghai (including those eligible for exemption under Order No. 26), and have passed the subject of Finance and Economic Laws and Regulations and Accounting Professional Ethics by July 1, 2013, but have not claimed their AQC, shall claim their AQC before the original qualifying result becomes invalid or before the expiry of the exemption clause.

Q11: Some applicants have obtained the qualifying result of certain APQE subjects in Shanghai before July 1, 2013, and have passed all the other subjects by December 31, 2014. When shall they claim their AQC?

A: All applicants who have passed certain subjects of APQE in Shanghai by July 1, 2013, and have passed all the other subjects by December 31, 2014 shall claim their AQC at the designated address specified by the administrative organ within six months after the final result is announced.

Those who fail to obtain their AQC within the specified time may claim one after passing some related training courses.

Q12: After the Implementing Measures enter into force, what shall applicants who have passed the APQE do to claim their AQC?

A: After the adoption of the Implementing Measures, any applicant who has passed APQE shall claim their AQC at the designated address specified by the administrative organ, and fill out an AQC holder information sheet. For this purpose, the applicant shall produce his valid and original ID credential and some related documents which shall include:

1. A certificate of belonging. If the applicant belongs to a work unit, he shall produce the tax registration certificate of the employer or the organization code of the public institution he works for; otherwise, he shall produce the valid household registration certificate or the original copy of his residence permit;

2. The original or duplicate copies of related credentials to support the information filled in the AQC Holder Information Sheet; and if the applicant commissions any agent to obtain his AQC, the valid and original ID of the agent and the letter of commission should be produced.

Q13: After the Implementing Measures come into effect, if any applicant has passed the APQE but failed to obtain their AQC before the deadline, can they still claim their AQC?

A: Those who have passed the APQE after July 1, 2013 but fail to claim their AQC before the deadline may still claim their AQC, but they need to attend and pass further training courses.

Q14: Where can the applicants who have passed the APQE claim and obtain their AQC?

A: Applicants who have passed the APQE can claim and obtain their AQC at the address designated by the administrative organ, and under Article 5 of the Implementing Measures, “Accounting practitioners who have appointment (employment) relationship with any entity, either an enterprise or a public institution, shall be subject to the jurisdiction of the administrative organ at the same level with the competent taxation authority; accounting practitioners who work for State organs or other public institutions shall be subject to the jurisdiction of the administrative organ at the same level with the budget allocating authority; accounting practitioners who work for any other organization in this City shall be subject to the jurisdiction of the administrative organ at the district or county level; and accounting practitioners who do not have appointment (employment) relationship with any entity but have permanent household registration in this City shall be subject to the jurisdiction of the administrative organ of the district or county where the household registration is filed; and accounting practitioners who have no permanent household registration in the city shall be subject to the jurisdiction of the administrative organ at the locality of residence.” About the specific address, applicants can refer to “Fiscal Administration: Qualification Approval of Accounting Practitioners” on the official website of Shanghai Municipal Finance Bureau.

Q15: If any accounting practitioner loses their AQC, can they apply for a replacement AQC? What should they do to obtain a replacement?

A: If any accounting practitioner loses their AQC, they must declare the loss with a public notice on a newspaper which nullifies that certificate. Then they shall fill out a form of application for replacement AQC which shall be submitted together with relevant supporting documents to the administrative organ. If those documentations are accepted and pass the review of the administrative organ, a replacement AQC shall be issued within 20 working days from the date of acceptance.

Relevant supporting documents include: valid original ID card, the original newspaper carrying the public notice declaring the loss, and the original and photocopy of receipts for making the notice. And if the application is made through an agent, the agent’s valid original ID card and Letter of Commission should be produced.

Q16: On what newspapers can any accounting practitioner who loses their AQC make the public notice to declare the loss?

A: A public notice declaring the loss of an AQC can be made on newspapers circulated in Shanghai Municipality or on professional accounting magazines, such as the Modern Accounting.

Q17: If any accounting practitioner damages their AQC, can they apply for a replacement?  What should they do to obtain the replacement?

A: If any accounting practitioner damages their AQC, they can apply for replacements, but they shall first fill out the Replacement Request Form, and then submit the Form together with the damaged original certificate to the administrative organ. The administrative organ shall review their application. If all documentations are verified and all requirements are met, the replacement certificate shall be issued within 20 work days after the date of acceptance.

Q18: How can accounting practitioners renew their AQC after expiry?

A: The AQC holder shall apply for renewing their AQC within 6 months before the certificate expires. They shall first fill out the Registration Form for Regular Replacement of the Accounting Qualification Certificate, and then submit their valid original ID credentials together with the form to the administrative organ.

Q19: What can accounting practitioners do who have failed to renew their AQC after expiry? 

A: If any accounting practitioner fails to renew their AQC within 6 months after it expires, they shall attend and pass relevant training courses and then renew their AQC.

Q20: Should any accounting practitioner who has obtained their AQC before July 1, 2013 update their AQC?

A: Any AQC holder who has obtained the AQC before July 1, 2013 shall update their AQC at the pertinent administrative organ of Shanghai. If any accounting practitioner fails to renew their AQC within 6 months after it expires, they shall attend and pass relevant training courses and then renew their AQC.

Q21: If anyone who is eligible to practice as an accountant and is still engaged in the accounting job but fails to obtain the AQC for various reasons, how can they apply for and obtain any AQC?

A: 1. Any applicant who has won the title as Senior Accountant before July 1, 2013, has been 50 years old and is still engaged in the accounting job may apply to the pertinent administrative organ for an AQC with necessary documentations. The administrative organ shall review their application, and if all requirements are met, an AQC shall be issued to the applicant. Names of applicants who have obtained the AQC in this way shall be made public on a designated online website.

2. Any applicant who has obtained a CPA certificate and is still engaged in the accounting job may apply to the pertinent administrative organ for an AQC with necessary documentations. The administrative organ shall review their application, and if all requirements are met, an AQC shall be issued to the applicant. Names of applicants who have obtained the AQC in this way shall be made public on a designated online website.

Applicants belong to the scenario 1 above shall submit their application to pertinent administrative organ which has jurisdiction over the employer they work for before December 31, 2014. If they fail to do so, they shall attend training courses before they can obtain the AQC.

Q22: What documentations are needed when any applicant who has won the title as Senior Accountant before July 1, 2013, has been 50 years old and is still engaged in the accounting job applies for their AQC?

A: Where any applicant who has won the title as Senior Accountant before July 1, 2013, has been 50 years old and is still engaged in the accounting job applies for AQC, they should produce: valid original identity card; Senior Accountant Qualification Certificate or the credential document to the same effect issued by pertinent qualification authorities and registered with the provincial human resource authority or the Ministry of Human Resources and Social Security (formerly the Ministry of Personnel); and original document of employment as senior accountant from the current employer and a photocopy of the document carrying the stamp of the human resources department of the employer.

Q23: What documentations are needed when any applicant who has practiced as an accountant for 20 years by July 1, 2013, has been 50 years old and is still engaged in the accounting job applies for their AQC?

A: Where any applicant who has practiced as an accountant for 20 years by July 1, 2013, has been 50 years old and is still engaged in the accounting job applies for AQC, they should produce: accounting vouchers, accounting books and accounting reports over the past 20 years carrying the signature of the applicant, or other credentials recognized by the administrative organ.

Q24: What documentations are needed when any applicant who has obtained the CPA certificate and is still engaged in accounting job applies for AQC?

A: Where any applicant who has obtained the CPA certificate and is still engaged in accounting job applies for AQC, they should produce: a valid original identity card, the original document of employment as accountant from the current employer, and the original CPA certificate. And the AQC shall be issued after all documents are verified by the administrative organ on http://cpaacc.mof.gov.cn.