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🇨🇳 China - Invoicing Specifications (Golden Tax System IV / e-Fapiao)

Status: 🔴 Mandatory Clearance (Fully Digitalized e-Fapiao) Authority: STA (State Taxation Administration) Platform: Leqi Platform (National E-Invoice Service Platform)

1. Context & Roadmap

China has transitioned from hardware-based invoicing (Tax Discs/U-Key) to a fully digitalized cloud system under Golden Tax System Phase IV. Crucial Shift: No more paper fapiao, no more special red stamps. The XML file is the invoice.

DateScopeObligation
ActivePilotMajor regions (Shanghai, Guangdong, etc.) already live.
Jan 1, 2026NationalFull mandatory adoption for nearly all businesses (B2B/B2C).
OngoingGTS IVAI-driven tax monitoring ("Managing tax by data").

2. Technical Workflow (Leqi Platform Clearance)

Emission is a real-time clearance process. You send data to the STA, and they return the signed, numbered invoice.

sequenceDiagram
    participant S as Invoicerr (Seller)
    participant Leqi as STA Leqi Platform
    participant B as Buyer
    
    Note over S: 1. Preparation
    S->>S: Generate XML (GB/T 38636)
    S->>S: Sign with SM2 (Chinese Crypto)
    
    Note over S: 2. Clearance
    S->>Leqi: Send XML via API
    Leqi->>Leqi: Check Quota (Credit Score)
    Leqi->>Leqi: Assign Invoice No + QR
    Leqi-->>S: Return Signed XML + OFD
    
    Note over S: 3. Delivery
    S->>B: Send OFD/XML (Email/App)
    Leqi->>B: Push to Buyer's "Tax Digital Account"

🧱 Key Components

  1. Fully Digitalized e-Fapiao: A structured XML file signed by the STA. It does not require a physical seal.
  2. Leqi Platform: The national cloud platform handling issuance, delivery, and validation.
  3. OFD (Open Fixed-layout Document): The Chinese standard for fixed-layout documents (like PDF). This is the visual representation sent to humans.
  4. SM Series Crypto: China uses national crypto standards (SM2, SM3) instead of RSA/SHA.

3. Quota Management (Dynamic Limits)

Unlike the old system (limit per invoice), the new system uses a Total Monthly Amount.

  • Dynamic: Your quota is determined by your Tax Credit Rating (A, B, M, C, D).
  • Risk: The AI monitors "Three Flows" consistency (Invoice, Cash, Goods). If suspicious, the quota is reduced instantly ("Sudden Reduction").

4. Red-Letter Fapiao (Credit Notes)

You cannot just issue a credit note. You must request a Red-Letter Information Sheet first.

  • If Buyer deducted VAT: Buyer must initiate the request.
  • If Buyer did not deduct: Seller initiates.
  • Workflow: Submit Info Sheet -> STA Validates -> Seller issues Red-Letter Fapiao.

5. Implementation Checklist

  • Middleware: Do not attempt direct API connection from overseas ERPs. Use a local middleware provider (e.g., Baiwang, Aisino) to handle SM2 crypto and API stability.
  • OFD Generator: Ensure the system can render/store OFD files.
  • Quota Monitor: Build a dashboard to track the remaining monthly invoice quota.
  • Red-Letter Logic: Implement the "Information Sheet" workflow before allowing negative invoices.
  • Archiving: Prepare for 30-year retention of XML files (not just OFD/PDF). Data must reside in China.

6. Resources