Direct answer

Manager is an officer role — ‘GM’ on a card does not bind the company unless chops, AOA or LR status say so.

Company Law provides for a manager appointed by the board (or the sole director) to run daily operations. The AOA and internal authorisation matrix decide what they can sign. They may also be the legal representative, but that is a separate SAMR registration. Labour-law GM contracts sit beside company-law office. Banks will ask for LR chop plus authorisation, not a LinkedIn title. This page is the officer. Directors and LR risk are related pages.

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

Is the GM also LR?

Check the licence.

LR
02

What can they sign without a board?

AOA and chop rules.

Authority
03

Employment vs office?

Labour overlay.

Labour
04

Who can fire them?

Board vs shareholder.

Removal

Working rule: Map the regulated role before marketing or launch in China.

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
English ‘CEO’ only
No SAMR/officer filing.
Authority gap.
GM holds all chops
Including LR chop.
Control concentration.
Labour-only firing
Ignoring company-law removal.
Two processes.
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.

01Licence and AOAOfficer map.
02Authorisation matrixContract value limits.
03Labour contractIf they are an employee.
Common confusions

Questions people ask before they build.

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

Must a WFOE have a GM?

Practice almost always names one. The AOA should say how they are appointed.

Can a foreign GM skip a work permit because they are an ‘officer’?

No. Immigration follows actual work in China.

Primary authorities

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