Editor's Note: Starting June 1, 2026, ten revised tax enforcement documents for inspections issued under Announcement No. 10 of 2026 by the State Administration of Taxation (SAT) will officially take effect. Following the 2024 amendments that aligned with the revised Administrative Reconsideration Law, this marks another significant update to the tax enforcement document system—advancing the standardization and normalization of tax inspection enforcement and adapting to new requirements for administrative inspections. Unlike the 2024 revision, this round focuses specifically on inspection-type documents. This article analyzes the key changes and highlights from the perspective of tax attorneys, and identifies critical practical considerations for businesses.

01  Background: A New Round of Tax Document Revisions Under Stricter Regulation of Business Inspections

Recently, the SAT issued the Announcement on Revising Certain Tax Enforcement Documents (SAT Announcement No. 10 of 2026). Looking back at recent revisions, in 2024 the SAT issued Announcement No. 1 of 2024, primarily to align with the newly amended Administrative Reconsideration Law and to strengthen administrative reconsideration as the primary channel for resolving administrative disputes. That revision covered tax handling decision notices, demand letters, enforcement decision notices, and simplified administrative penalty decisions—but did not include inspection-type documents. Announcement No. 10 of 2026 now targets precisely those inspection documents, complementing the 2024 revision in terms of document type. Therefore, the appropriate baseline for comparing this revision is the earlier SAT Announcement No. 23 of 2021.

Two key institutional developments inform this revision. First, in January 2025, the General Office of the State Council issued Opinions on Strictly Regulating Administrative Inspections of Enterprises (Guoban Fa [2024] No. 54), which explicitly requires relevant authorities to publish the annual frequency cap for inspections of the same enterprise by the same agency, to issue an administrative inspection notice when conducting an inspection, and that enterprises have the right to refuse and report inspections conducted in violation of regulations. The Opinions also established five prohibitions—against profit-motivated inspections, interference with business operations, arbitrary penalties, setting inspection quotas, and disguised inspections—and required inspection frequency to be included in the annual administrative enforcement statistics report. Second, in April 2025, the Ministry of Justice issued the Basic Format Templates for Administrative Inspection Documents (Trial), establishing seven nationally uniform inspection document types, embodying the core principles of 'all inspections require prior approval,' 'all inspections require advance notice,' and 'all rights and responsibilities must be disclosed.' These principles are systematically reflected and implemented in this round of tax document revisions.

Against this backdrop, Announcement No. 10 of 2026 abolishes the corresponding legacy inspection documents from Announcement No. 23 of 2021 and establishes a new set of ten documents covering the full inspection lifecycle: pre-inspection approval, inspection notice, process records, recusal handling, and result notification. The following sections analyze the major highlights from a tax attorney's perspective and identify key practical considerations for enterprises.

02  Highlight 1: All Inspections Require Formal Approval — Department-Level Supervisors No Longer Sufficient

Compared to the 2021 version, the Tax Inspection Approval Form is an entirely new document. In terms of content, the form first identifies the source of the inspection task. Sources fall into two categories: (1) routine inspections and special inspections; and (2) complaints and reports, transferred or assigned cases, risk scanning, audit evidence collection, cross-regional cooperation, implementation of international treaties, and other circumstances (multiple selections permitted). The form also includes an inspection frequency field requiring entries for 'Annual administrative inspection frequency cap: ___ times; this is the ___th inspection,' with a note that inspections exempt from the annual frequency cap need not fill in specific figures. Inspections falling under category (2)—those triggered by complaints, transfers, risk scans, audit evidence collection, cross-regional cooperation, or international treaties—are not subject to the frequency cap and may leave the frequency field blank. Additionally, the form includes a field for inspection method, with options for on-site and off-site inspections.

Regarding procedural constraints, Item 3 of the usage instructions states: 'All inspections require approval. In principle, each matter requires separate approval, and approval must be obtained in advance. In urgent situations requiring immediate action, the matter must be promptly reported and approval procedures completed after the fact.' This establishes the prior-approval principle—even emergency inspections must be retroactively approved; uninspected inspections without prior approval are prohibited. Item 9 further specifies that 'The Tax Inspection Approval Form must be approved by the principal or a deputy responsible officer of the agency; approval by the head of an internal department alone is not permitted.' This directly corresponds to the requirements of Guoban Fa [2024] No. 54, elevating the approval authority to the bureau leadership level—section chiefs and division directors of internal departments may no longer independently approve inspections, significantly raising the threshold for initiating an inspection.

Overall, the Tax Inspection Approval Form consolidates the legal basis, task source, and frequency information for each inspection into the internal approval record, creating a traceable documentary basis for subsequent enforcement accountability and compliance review. It is not merely an internal administrative document—it functions as a pre-inspection gate constraining the exercise of inspection authority.

03  Highlight 2: Inspection Frequency Now Disclosed to Taxpayers; New Rights to Request Recusal and to Supervision and Redress

The revised Tax Inspection Notice differs significantly from the 2021 version. The old version merely listed the assigned personnel, inspection time period, and a single notice of the right to refuse inspection. The new version substantially expands the substantive content, making it one of the most consequential documents for taxpayer rights in this revision.

First, the fields to be completed are more detailed. The inspection start time is now recorded to the hour and minute, enabling calculation of total inspection duration—this feeds into big data systems for frequency monitoring and makes anomalous conduct such as nighttime inspections easier to detect. The form now requires the inspection method to be specified. 'Inspection location' is added as a mandatory field, limiting the scope of the inspection so that it cannot be arbitrarily extended to premises not listed in the notice. The request for materials has been revised from 'provide relevant materials' to 'provide relevant materials (with an attached list of materials and items),' allowing taxpayers to refuse requests for items not on the list.

Second, frequency information is disclosed to taxpayers for the first time. The revised notice adds 'Annual administrative inspection frequency cap: ___ times; this is the ___th inspection,' as well as a check-box field for the source of the task (complaints/reports, risk scanning, etc.). Previously, frequency information existed only in internal approval documents and was inaccessible to taxpayers. Now, taxpayers can directly verify from the notice whether the current inspection exceeds the frequency cap, protecting their right to be informed. It should be noted, however, that when used by tax inspection bureaus, the notice is not subject to routine frequency limits; the frequency regulation applies only to routine inspections conducted by regular tax bureaus.

Third, the rights notice has expanded from one item to three. The existing right to refuse inspection is retained—taxpayers may refuse an inspection if no tax inspection certificate and notice are presented. A right to request recusal is newly added: 'If the inspected party believes that a tax inspection official has a direct interest in or other relationship with the inspection that may affect impartial enforcement, the party may apply for recusal. A decision on whether to grant recusal will be made and communicated within 3 days; the inspection will not be suspended during the recusal review period.' This provision requires a decision within 3 days and corresponds institutionally to the newly added Recusal Review Decision Notice discussed below. A right of supervision and redress is also newly added: 'The inspected party has the right to supervise the entire tax inspection process and, if the inspection is believed to infringe upon its lawful rights and interests, has the right to file a complaint or report and to seek legal redress.' Together, these three rights notifications transform taxpayers from passive subjects of inspection to active supervisors.

Fourth, the usage instructions contain several additional procedural constraints. On the identity of personnel, the new version requires that at least two names and tax inspection certificate numbers be entered in the field 'designated inspectors: ___'; the added certificate numbers allow taxpayers to verify the identity of enforcement officers and help detect impersonation. On inspection methods, 'off-site inspections' (e.g., video conferencing) are for the first time included in the usage instructions alongside on-site methods (reviewing and copying materials, interviews, sampling, on-site surveys, etc.), providing documentary authority for newer inspection modalities. Notably, when the notice is used by tax inspection bureaus, they may omit the specific inspection method, the frequency information, and the task source paragraph.

04  Highlight 3: Recusal Procedure Now Formally Documented; Decision Required Within 3 Days with Stated Avenues for Redress

The 2021 version contained no Recusal Review Decision Notice for Tax Officials. Although the recusal mechanism has long existed under Article 12 of the Tax Collection and Administration Law (TCAL), the absence of a dedicated document and clear time limits meant that in practice applications were routinely handled verbally or left indefinitely pending—'verbal denials' or 'no response' were common. The introduction of this document formally brings the recusal procedure into the realm of legal documentation.

First, the scope of application is well-defined, with clear legal authority. The document is grounded in Article 12 of the TCAL (recusal of tax officials) and Article 43 of the Administrative Penalty Law (recusal in administrative penalty proceedings). This means the document applies not only to tax inspections but also to recusal applications arising in the context of administrative penalties.

Second, consistent with the Tax Inspection Notice's statement that 'a decision on whether to grant recusal will be made and communicated within 3 days; the inspection will not be suspended during the recusal review period,' the tax authority is required to make and communicate a recusal decision within 3 days. Previously, without a time limit, indefinite delay was effectively a disguised refusal; the 3-day deadline gives taxpayers a quantifiable waiting period, and once it is exceeded, administrative reconsideration or litigation becomes available. The non-suspension rule during the review period derives from Article 43(2) of the Administrative Penalty Law and is institutionally justified as preventing the use of recusal applications to delay inspections. A potential issue, however, is that if a recusal application is ultimately granted, the legal effect of evidence collected during the review period remains unclear under current law—a potential flashpoint for future disputes.

Third, both approvals and denials carry rigid requirements. Where recusal is granted, the replacement official must be confirmed in writing (with name and certificate number filled in); a verbal response is insufficient. Where recusal is denied, the decision must cite a specific legal provision ('does not meet the recusal conditions under ___ [provision]'); a generic statement that 'conditions are not met' is impermissible. This directly limits the space for arbitrary denials.

Fourth, avenues for redress are clearly stated. The document notes that 'if the party disagrees with this decision, it may seek legal redress in accordance with law,' placing recusal decisions within the category of administrative acts subject to reconsideration and judicial review. Parties may seek administrative reconsideration or administrative litigation to challenge a denial of a recusal application.

05  Highlight 4: On-Site and Interview Records Now Include Scripted Procedural Notifications; Right to Make Statements and Objections Must Be Recorded

The 2021 version of the On-Site Inspection Record consisted primarily of a blank recording area, with procedural requirements scattered only in the usage instructions and not embedded in the substantive text. The new version introduces a scripted opening directly in the main body: 'Tax enforcement officer: Hello! We are tax enforcement officers from [enforcement authority]. Here are our tax inspection certificates (present certificates). Please confirm. Inspected party: ☐ Confirmed / ☐ Not confirmed. Tax enforcement officer: We are now conducting on-site enforcement in accordance with law regarding [party / specific matter]. Please cooperate. You have the right to make statements and objections regarding matters arising during the inspection. (If audio-visual recording is being used, the recording should be disclosed.)'

This script embeds three procedural requirements for lawful enforcement—presenting credentials, stating the purpose, and informing the right to make statements and objections—directly into the document format. By completing the form, the officer simultaneously satisfies the procedural requirements; the document itself becomes evidence of procedural compliance. The protection of the right to make statements and objections is particularly noteworthy. The old version merely required rights and obligations to be communicated in general terms in the usage instructions; the new version explicitly states in the body 'you have the right to make statements and objections,' and adds a check-box at the end of subsequent pages for recording statements and objections (☐ None / ☐ Present), which the officer must explicitly select. The right to make statements and objections is thereby elevated from 'may be recorded' to 'must be recorded,' preventing officers from selectively ignoring objections and bringing the protection of this right at the inspection stage to the same standard of rigor as in administrative penalty proceedings.

Additionally, the usage instructions add that 'on-site inspections shall not deliberately require the legal representative to be present,' targeting two specific abuses: intentionally delaying by waiting for the legal representative to arrive, or pressuring a company by insisting the legal representative must attend. On audio-visual recording, the new body script reminds officers to disclose recording; the usage instructions add that 'where the inspection process is synchronously audio-visually recorded, the relevant recordings shall be archived together,' integrating audio-visual records into the formal document system—the archiving requirement makes them retrievable as evidence and prevents selective disposal of unfavorable recordings. The procedure for confirming corrections to records has also been expanded from the old version's requirement of 'a fingerprint impression at the point of change' to three options: signature, fingerprint, or seal—lowering the threshold for confirmation and accommodating the varying practical capabilities of different parties.

At the same time, the Interview Record has been standardized to a uniform national format for the first time. The new version introduces several elements: a check-box identifying the capacity of the person being interviewed—legal representative, actual controller, financial officer, tax handler, tax agent, or other—clarifying the identity of the interview subject and providing a basis for subsequent proceedings; a standardized opening script identical to that in the On-Site Record, requiring credentials to be presented and confirmed, formalizing the procedure for identifying enforcement personnel and preventing impersonation; and dual notification of rights and obligations as well as the right to apply for recusal. On signatures and fingerprints, the old version had no uniform national requirement; the new version specifies that both a signature and fingerprint impression are required.

06  Highlight 5: Closed-Loop Notification of Inspection Results; 'No Issues Found' Can Be Used to Counter Repetitive Inspections

The 2021 version contained no Tax Inspection Result Record. This was a notable gap in the old framework: if an inspection concluded without findings, the enterprise received virtually no written feedback; a state of 'inspection without resolution' troubled large numbers of inspected businesses, and inspection results left no traceable documentation. The addition of this document fills an important institutional void.

In terms of document design, the form is prepared in duplicate—one copy delivered to the inspected party and one placed in the case file. The inspected party's right to retain a copy is a design feature that directly grants the inspected party the right to hold a results document in the tax inspection context, providing direct evidence for any subsequent rights-protection measures. On conclusions, the form explicitly lists the options '☐ No issues found' and '☐ The following issues were identified upon inspection.' The 'no issues found' option is particularly significant: a tax authority's issuance of a 'no issues' document is effectively a written clearance, and the inspected party may invoke it to argue that the same matter cannot be subject to a repeat inspection—effectively countering cyclical repetitive inspections.

On the notification procedure, the form requires that 'where inspection results can be communicated on the spot, they shall be communicated on the spot; where they cannot, they shall be communicated promptly,' establishing a time requirement for result notification and ending the previous practice of inspections 'fading away without resolution,' making the duty to notify of inspection results enforceable. The form also provides that 'where inspection results are uniformly published through an information platform, the inspected party shall be informed at the time of inspection of the means of inquiry,' enabling parties to independently look up inspection results through the digital regulatory system and increasing enforcement transparency. Furthermore, the form specifically notes '(this section records factual inspection findings only),' restricting inspectors from including legal evaluations or inferences in the record and preventing subjective judgments from being embedded in objective records.

Overall, this new document establishes a closed loop for notifying parties of inspection results: regardless of whether issues are found, a record must be delivered to the inspected party. If the record states 'no issues found,' the inspected party may use it to resist repeat inspections covering the same period and the same matter, effectively curbing abuses such as repeated inspections or indefinitely suspended inspections.

Conclusion

Taken as a whole, the core logic of the ten revised tax enforcement documents under Announcement No. 10 of 2026 can be summarized as follows: translating the macro-level requirements for regulating administrative inspections of enterprises into concretely operable document formats, so that taxpayers' procedural rights have written authority and documentary proof. For enterprises, understanding these document changes is not only the foundation of compliance management but also a prerequisite for actively protecting their own rights when facing tax inspections. Upon receiving an inspection notice, enterprises should immediately verify whether the frequency cap has been exceeded, whether inspectors' credentials are in order, and whether the notice specifies a list of required materials. During the inspection, attention should be paid to whether the scripted procedural steps are performed and whether the right to make statements and objections is recorded. After the inspection, the Inspection Result Record must be obtained and carefully preserved—especially any finding of 'no issues.' It should be noted that tax inspections often involve complex procedural judgments and assessments of evidentiary effect that are difficult for enterprises to navigate alone. The timely involvement of professional tax attorneys can help enterprises identify and record key procedural points on the spot and respond in a calibrated manner, avoiding the loss of later remediation opportunities through missteps in the initial response. For tax attorneys, the new document framework provides richer entry points for procedural review—particularly given that multiple documents now expressly state avenues for redress, making taxpayers' procedural rights more practically actionable. Overall, this revision uses documents as the lever to advance tax inspections from the exercise of authority toward the regulated exercise of authority.