SAMR Consults on Draft Revised Guidelines on Overseas Antitrust Compliance
市场监管总局关于公开征求《企业境外反垄断
合规指引（修订草案征求意见稿）》意见
的公告
Issuing authority
市场监管总局 (State Administration for Market Regulation)
Document type
draft
Publication date
2026-09-22
Deadline
2026-09-29
What happened
On 2026-09-22, the State Administration for Market Regulation (市场监管总局) issued 《市场监管总局关于公开征求《企业境外反垄断合规指引（修订草案征求意见稿）》意见的公告》, launching a public consultation on the draft revision of the 《企业境外反垄断合规指引》.source The draft, titled 《企业境外反垄断合规指引（修订草案征求意见稿）》, is intended to further guide Chinese enterprises in enhancing overseas antitrust compliance awareness and preventing related legal risks.source The regulator is accepting feedback through its official website, a dedicated email address, and postal correspondence.source
Who is affected
Chinese enterprises with international operations and their antitrust compliance officers are directly affected, because the draft guidance is aimed at helping domestic firms strengthen overseas antitrust compliance awareness and prevent related legal risks.source Any business, trade association, or advisory firm with an interest in overseas antitrust compliance standards for Chinese companies should consider submitting comments before the deadline.
What to do
Review the 《企业境外反垄断合规指引（修订草案征求意见稿）》 and its drafting explanation on the SAMR website to understand the proposed changes to the 2021 guidelines.source
Submit feedback to 市场监管总局 through one of the three designated channels—the official website “征集调查” portal, email to jyzjz@samr.gov.cn with the required subject line, or post to the Beijing address specified in the notice—before the comment deadline.source
Conduct a gap analysis between existing overseas antitrust compliance programmes and the draft requirements to identify areas where current policies may need updating.
Coordinate with external counsel or industry peers to consolidate technical comments and submit them within the short consultation window.
Key dates
2026-09-22: 市场监管总局 published the consultation notice and draft.source
2026-09-29: Deadline for public comments on the draft guidance.source