Preface

After an enterprise enters the bankruptcy reorganization procedure, it often faces restrictions on many business matters such as bank loans, registration, and qualification review due to the impairment of corporate credit, making it difficult to carry out new production and business activities. To avoid falling into operational difficulties again, the credit repair of bankrupt and reorganized enterprises is particularly important. In practice, the credit repair of bankrupt and reorganized enterprises mainly proceeds from four aspects: tax credit repair, industrial and commercial credit repair, financial credit repair and judicial credit repair.

I. Tax Credit Repair

Legal Basis

Pursuant to Article 1 of Announcement of the State Taxation Administration on Matters Relating to the Evaluation and Repair of Tax Credit (Announcement No. 31 of the State Taxation Administration, 2021), if a bankrupt enterprise or its administrator has lawfully paid taxes, late fees, fines and corrected the relevant acts of dishonesty in tax credit during the reorganization or conciliation procedure, it may apply to the competent tax authority for tax credit repair.

Types of Repair

The "Scope and Standards for Tax Credit Repair" attached to the Announcement divides tax credit repair into two types:

• Repair with Bonus Points: For 15 circumstances such as "failure to file tax returns within the prescribed time limit", if the act is corrected during the bankruptcy procedure, the repair standard for the deduction indicator shall be deemed as correction within 30 days, and bonus points shall be given according to the highest score.
• Directly Rated as D: For 5 circumstances such as "taxpayers with records of abnormal household status", they are not subject to the condition of having no new records of dishonest tax credit acts for 12 consecutive months before the application.

Reorganized enterprises enjoy relatively greater convenience in tax credit repair.

Application Materials

In the operation of applying for tax credit repair for reorganized enterprises, the following shall be submitted:

• Civil ruling of the people's court confirming the completion of the execution of the reorganization or conciliation plan

• Power of attorney for the handler and identity documents

• Fill in the Application Form for Tax Credit Repair as required

Latest Developments

According to Article 25 of Measures for the Administration of Tax and Payment Credit (Announcement No. 12 of the State Taxation Administration, 2025), after an enterprise enters the bankruptcy reorganization or conciliation procedure, if the enterprise or its administrator has lawfully paid taxes and fees, interest, late fees, fines and corrected the relevant acts of dishonesty in tax and payment, it may apply for credit repair in accordance with the repair standards applicable to bankrupt and reorganized enterprises, and shall provide the reorganization plan approved by the people's court or the conciliation agreement recognized by the people's court. The competent tax authority shall complete the review within 15 working days from the date of accepting the application.

II. Industrial and Commercial Credit Repair

Policy Basis

Regarding the industrial and commercial credit repair of bankrupt and reorganized enterprises, the State Council, in the Opinions on Carrying out Pilot Work for Optimizing the Business Environment (Guo Fa〔2021〕No. 24) issued on November 25, 2021, emphasized the establishment and improvement of a credit repair mechanism for enterprise bankruptcy reorganization. All regions have entered a stage of exploration one after another, and many places have issued corresponding policies successively.

Local Practices

• Shiyan City: Issued the "Measures for Credit Repair of Bankrupt Reorganized and Conciliated Enterprises in Shiyan City". A reorganized enterprise or its administrator shall apply to the Municipal Development and Reform Commission for enterprise credit repair by holding an application form and a ruling of the people's court approving the reorganization or conciliation plan. The Municipal Development and Reform Commission shall share the credit repair information of reorganized and conciliated enterprises with relevant departments. In accordance with the enterprise's application for credit repair, the market supervision department shall, in accordance with the Measures for the Administration of Credit Repair by Market Regulation Departments, remove eligible enterprises from the list of abnormal business operations or the list of seriously illegal and dishonest entities, lift relevant management measures, and announce them through channels such as the National Enterprise Credit Information Publicity System.

• Beijing Municipality: Issued the "Several Measures for Further Optimizing the Business Environment to Promote and Guarantee the Lawful Performance of Duties by Administrators in Bankruptcy Proceedings", clarifying that if a reorganized enterprise that meets the conditions applies to the market supervision department for credit repair, the market supervision department shall, within 15 working days from the date of acceptance, take measures such as removing the reorganized enterprise from the list of abnormal business operations and prematurely removing it from the list of seriously illegal and dishonest entities.

Application Materials

In the industrial and commercial credit repair of reorganized enterprises, the main materials to be submitted are:

• Civil ruling accepting the application for reorganization
• Civil ruling approving the reorganization plan (draft) or confirming the completion of the execution of the reorganization plan and terminating the reorganization procedure
• Supervision report issued by the administrator of the bankrupt reorganized enterprise
• Identity certification materials of the legal representative, power of attorney and identity certification materials of the trustee submitted by the bankrupt reorganized enterprise at the time of application
• Credit Repair Application Form, Commitment Letter of Trustworthiness and other materials

Latest Regulations

Article 20 of the Measures for the Administration of Credit Repair by Market Regulation Departments (implemented on December 25, 2025) specifically stipulates the credit repair of bankrupt reorganized enterprises:

During the execution of the reorganization plan or conciliation agreement, the reorganized enterprise or its administrator may, by holding the ruling of the people's court approving the reorganization plan or recognizing the conciliation agreement, apply to the market supervision department for credit repair. The market supervision department shall, within 10 working days from the date of receiving the application, temporarily shield the illegal and dishonest information and temporarily lift the restrictive measures that may affect the execution of the reorganization plan or conciliation agreement in accordance with the principle of minimum necessity.

The time limit for the repair of administrative penalties and the list of seriously illegal and dishonest entities has been reduced to 7 working days, and the removal from the list of abnormal business operations shall be completed within 2 working days.

III. Financial Credit Repair

Difficulties in Repair

One of the biggest difficulties for bankrupt and reorganized enterprises to continue their economic activities is the difficulty in financing. If the repair of financial credit cannot be resolved, bankrupt and reorganized enterprises cannot be truly revitalized. In practice, the reorganization method of continuing to use the original name objectively results in the financial credit reporting system being unable to distinguish between enterprises before and after bankruptcy reorganization. Banks can only treat reorganized enterprises differently from normal enterprises and continue to include them in the list of financial dishonesty.

Local Explorations

All regions have carried out explorations to varying degrees on the financial credit repair of bankrupt and reorganized enterprises. Most of them allow financial credit repair after the completion of the execution of the reorganization plan, but the repair method is mainly carried out by means of "adding major events", and there are still situations where financing is hindered in practice.

• Jiangsu, Shiyan and other places: Have issued relevant policies in the exploration of financial credit repair for bankrupt and reorganized enterprises, urging financial institutions to support the normal financing needs of successfully reorganized enterprises, and not to reject them outright due to the original bad credit records in the credit reporting system.