Qualification by Work Experience for Senior Executives of Private Fund Managers: Latest Steps and Timeline (September 2026)

2026.09.17 · Professional Articles · Private Funds

Jiao Liang's team recently completed a legal opinion project for the certification of a private fund manager's senior executive through recognition of work experience. This article sets out the main steps, the time required at each stage (about four weeks in total), the eligibility and integrity requirements, and the additional requirements for key management executives.

Jiao Liang’s team recently completed a special legal opinion project for the certification of fund practitioner qualification of a senior executive of a private fund manager through recognition of prior work experience. The project was reviewed and approved by the Asset Management Association of China (AMAC) and completed on the AMAC public disclosure platform, with the senior executive obtaining fund practitioner qualification by way of “qualification recognition”.

For private equity fund managers (including venture capital fund managers), a proposed senior executive who meets the prescribed conditions may obtain fund practitioner qualification without examination through “recognition of work experience”. Based on the handling of this project, the main steps and the timeline are set out below.

1. Main steps

1. The manager appoints the proposed senior executive, signs an employment contract and specifies the executive position;
2. Collect certificates of work experience issued by each former employer; the manager contacts those employers to verify the employment information;
3. Appoint a law firm filed with the CSRC to carry out verification and issue a special legal opinion;
4. After the legal opinion is sealed, the applicant submits the registration application through a personal account and the institution confirms it through the institutional account;
5. AMAC approves and publishes the registration; fund practitioner qualification is obtained;
6. The institution begins the major change registration for “change of information on directors, supervisors, senior managers and investment personnel”;
7. Within 60 days from the date of first registration of the qualification, complete no less than 15 hours of follow-up professional training.

2. Timeline (experience from a September 2026 case)

The timeline depends on the quality of the underlying materials: where certificates of experience are missing, where the chronology is inconsistent, or where integrity checks reveal matters requiring disclosure, the process takes correspondingly longer. The above reflects a single case and does not constitute a commitment as to timing.

3. Eligibility and integrity requirements

Under the Rules for the Management of Fund Practitioners and the Provisions on Matters Concerning the Implementation of the Rules for the Management of Fund Practitioners (both in force since 24 November 2023):

• the proposed senior executive must have more than 10 years of work experience in securities, funds, finance, law, accounting or comparable fields; and
• within the past five years the applicant must not have been subject to administrative penalties or administrative regulatory measures by financial regulators, nor to self-regulatory sanctions or self-regulatory management measures by financial industry self-regulatory organisations.

4. Additional requirements for key management executives

In addition to the qualification recognition conditions, the proposed legal representative, the executor or its appointed representative, the person principally responsible for operations and management, and the senior manager responsible for investment management must also satisfy the requirements of the Measures for the Registration and Filing of Private Investment Funds (AMAC [2023] No. 5) and Guideline No. 3 for the Registration of Private Fund Managers:

1. Position experience. The above persons of a private equity fund manager must have more than five years of experience in equity investment management or relevant industry management; the compliance and risk control officer must have more than three years of experience relating to investment in law, accounting, auditing, supervision, inspection or comparable fields, or in compliance, risk control, regulation and self-regulation in the asset management industry; and the senior manager responsible for investment management must also have a compliant investment management track record.
2. Qualification and practice conditions. They must meet the fund practitioner qualification and practice conditions prescribed by the CSRC and AMAC, and have operational and management capability commensurate with the proposed position.
3. Restrictions on concurrent positions. They must not hold concurrent positions in non-affiliated private fund managers, conflicting-business institutions or other institutions where there is a conflict of interest with their institution, or become the controlling shareholder, actual controller or general partner of such institutions; the compliance and risk control officer must not engage in investment management business, hold positions conflicting with compliance and risk control duties, or hold concurrent positions in other for-profit institutions.
4. Stability of appointment. Before the first private fund completes filing, the legal representative, the executor or its appointed representative, the person principally responsible for operations and management, the senior manager responsible for investment management and the compliance and risk control officer must not be replaced.

Note. The “more than 10 years of work experience” test for recognition of work experience and the “more than five years of position experience” test for registration and filing are two different standards and are not interchangeable.

5. Two practical points

1. Certificates of work experience must be issued by the former employer; business cards or similar cannot substitute for them;
2. The 60-day training deadline runs from the date of first registration shown on the practitioner management platform, so training should be arranged promptly after approval.

Sources. The Rules for the Management of Fund Practitioners, the Provisions on Matters Concerning the Implementation of the Rules for the Management of Fund Practitioners, the Measures for the Registration and Filing of Private Investment Funds (AMAC [2023] No. 5) and their supporting guidelines are all currently in force. This article does not constitute formal legal advice, and project information has been anonymised.

原文为中文专业文章，由焦梁律师团队微信公众号「焦梁商事金融律师团队」发布。 The original article was published in Chinese by the Jiao Liang Commercial & Financial Lawyers Team WeChat account.

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