The classification screen

4 questions before you choose the route.

This page identifies the right question and evidence. It does not determine the legal outcome on a reader’s facts.

01

Where are the assets and subsidiaries?

Map.

Map
02

Foreign main proceeding recognised?

Recognition.

Recog
03

Local China filing needed?

Parallel.

Local
04

Buyer path vs claim path?

Resolve the buyer path vs claim path question separately before choosing the route.

Deal

Working rule: When debtors span borders, China practice involves recognition/assistance questions, parallel enterprise-bankruptcy filings, and practical control of PRC assets, banks and subsidiaries.

What changes the answer

The signal ledger.

These facts move the question beyond a label and into a product, money-flow and control analysis.

Signal
Ask the operating question
Why it changes the route
Assume foreign order binds PRC register automatically
Unreliable.
Local process.
Ignore China subsidiary ring-fence
Asset miss.
Map entities.
Skip claims deadline in PRC case
Process miss.
File.
Prepare before you escalate

Bring a compact evidence docket—not a pitch deck.

Give a compliance team or counsel the operating facts that reveal the perimeter.

01Foreign court ordersProceeding.
02China asset/title listSitus.
03Service/authentication packProof.
Common confusions

Questions people ask before they build.

Short answers for orientation. The right result can change with the service model and current rules.

Does China apply UNCITRAL Model Law wholesale?

Do not assume full adoption — use current judicial practice with counsel.

Where is distressed M&A?

Use the linked specialist resource when Cross-Border Insolvency in China turns on detailed evidence, procedure or risk assessment.

Primary authorities

Reviewed sources support orientation, not a fact-specific assessment.

Supreme People’s Court
National laws database — Enterprise Bankruptcy Law (NPC)
SAMR enterprise registration
Ministry of Human Resources and Social Security (employee claims)