In 2025, many countries finalized regulations and released new guidance regarding global equity plans. Multinational companies should confirm whether their equity grant materials and plan administration align with such updates, especially if equity grants are expected during Q1 2026. Given the frequent overlap between global equity compensation and global employment laws, it is also recommended that in-house counsel teams collaborate to ensure equity grant materials comprehensively address any employment-related matters. This summary highlights selected updates and global trends that many companies are currently addressing.
For equity plans registered with China’s State Administration of Foreign Exchange (China SAFE), companies were previously required to submit quarterly activity reports. Effective Q3 of 2025, this requirement has been eliminated.
Next steps: This has been a welcome change for most companies. While the quarterly report was a fairly straightforward activity report, the submission required reconciling data with payroll and amounts transferred through the local China bank account. Please note that material plan changes (e.g., amendments to material plan terms, termination/deregistration, bank changes) should continue to be reported to China SAFE.
Previously, China SAFE imposed a policy that required terminated employees to sell all shares and remit the proceeds through the China SAFE account within six months of termination (the “six-month forced...
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