Paid-in is evidence of money (or valued assets) received — it is not the registered-capital line on the licence.
Paid-in (实缴) capital is the amount actually contributed. For FIEs it usually shows up through the capital account and bank receipts; in-kind needs valuation and transfer of title. Formal capital-verification reports are no longer universal, but banks, SAMR disclosure and counterparties still ask for proof. Unpaid subscribed amounts remain a shareholder debt. FX contribution mechanics live on /china-fx-route-capital-contribution. Do not Photoshop a bank slip.
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.
What does the bank file show?
SWIFT, capital-account, RMB receipt.
BankAny in-kind actually transferred?
Title vs promise.
In-kindDoes SAMR disclosure match?
Annual report / publicity system.
PublicGap vs subscribed?
Five-year clock.
GapWorking rule: Map the regulated role before marketing or launch in China.
The signal ledger.
These facts move the question beyond a label and into a product, money-flow and control analysis.
Bring a compact evidence docket—not a pitch deck.
Give a compliance team or counsel the operating facts that reveal the perimeter.
Questions people ask before they build.
Short answers for orientation. The right result can change with the service model and current rules.
Do we still need a CPA verification report?
Not as a universal Company Law step. Banks and some licences still ask. Confirm the counterparty.
Can we count a shareholder loan as paid-in?
Generally no. Loan is debt; capital is equity.
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.
