Summary
Compare China ecommerce accounting providers in two stages: verify the statutory entry gate, then run one anonymized trial close. The winning team should map every store, legal entity, settlement currency, inventory location, journal, and tax record; deliver reproducible files; explain open differences; and accept written data-return and termination duties before any full handover begins.
Which qualification gate comes before price?
The first gate is legal qualification for the work actually being delegated, followed by a match between the licensed party, contract party, and delivery team. China’s Ministry of Finance Order No. 98, issued on 14 March 2019, says an agency other than an accounting firm needs the prescribed agency-bookkeeping license to conduct agency bookkeeping.
Order No. 98 also sets a baseline of at least three full-time practitioners and requires the person responsible for agency bookkeeping to hold the relevant accountant-level professional qualification or have at least three years of accounting experience. Those thresholds establish entry, not expertise in Amazon, Shopify, TikTok Shop, bonded imports, overseas warehouses, or multicurrency settlements.
Verification should compare the license name and unified social credit code with the proposed contract, invoice issuer, bank beneficiary, and named engagement lead. A candidate that cannot make those identities consistent should not receive live store credentials or a full accounting archive, regardless of a lower annual quote.
What must a trial close prove before a full switch?
A trial close must prove that the team can turn the same source population into a traceable entity-level ledger and explain every remaining difference. Give each candidate one closed month containing at least one normal sale, refund, platform fee, reserve or deduction, foreign-currency payout, inventory movement, and intercompany item.
The trial pack should identify store ID, platform entity, contracting entity, settlement account, bank account, invoice issuer, tax registration, warehouse, and journal destination. A subtotal that combines two legal entities may be operationally convenient, but it cannot support entity accounts until the allocation rule and source identifiers are visible.
| Test | Evidence expected | Fail condition |
|---|---|---|
| Store ownership | store-to-entity-to-account map | one store appears under two entities without dates |
| Settlement close | gross-to-net payout bridge | bank receipt posted directly as sales |
| Inventory close | SKU and warehouse roll-forward | plug entry has no movement support |
| Tax linkage | invoice and filing references | tax totals cannot return to ledger data |
How do you test ownership of accounting data and workpapers?
Data ownership is tested by asking whether the business can export, interpret, back up, and hand the records to another qualified team without the former provider’s login. Cai Kuai [2024] No. 11, issued by the Ministry of Finance on 26 July 2024, defines accounting-software functions to include direct data collection and the generation, storage, conversion, output, analysis, and use of vouchers, books, and reports.
Article 13 calls for standardized account structures, accounting processes, financial master data, reports, and technical and data standards. For a multi-store group, a usable handover therefore needs more than PDF statements: it needs the store dictionary, entity codes, account mapping, transformation rules, source exports, journal files, and a list of manual adjustments.
Article 31 addresses formation, collection, organization, archiving, use, and protection of electronic accounting materials, while Article 38 requires backup arrangements covering method, frequency, medium, and retention period. A provider comparison should score whether those controls belong to the business and remain operable after termination.
Which contract clauses keep the eventual exit possible?
The contract should make five exit-critical subjects explicit: responsibility for accurate and complete records, transfer and receipt procedures, financial-report requirements, archive custody, and accounting handover at termination. Ministry of Finance Order No. 98 lists those subjects in Article 12 for written agency-bookkeeping engagements.
Operational schedules should then name concrete deliverables and dates: source-file receipt by the fifth working day, exception list by the eighth, reviewed close pack by the twelfth, and archive export within 10 working days after termination are possible examples. The numbers are negotiable examples, but each deadline needs a file, owner, reviewer, and escalation path.
Cai Kuai [2024] No. 11 Article 15 adds a related control when accounting systems are externally developed, purchased, or rented: contracts should address service content, quality, timeliness, data security, rights, and responsibilities. Engagement terms should therefore cover accounting work and system access separately instead of assuming a bookkeeping clause also resolves cloud-data ownership.
Exit language should specify formats such as CSV, XLSX, PDF, original electronic vouchers, database export where applicable, and an index that connects every file to entity and period. The agreement should also bar deletion or credential revocation until both sides sign the archive inventory and opening-balance exception list.
How should multicurrency capability be tested?
Multicurrency capability should be tested by separating transaction currency, settlement currency, bank-account currency, functional currency, and presentation currency. IAS 21 defines functional currency as the currency of the primary economic environment in which an entity generates and expends cash; every other currency is foreign to that entity.
A candidate should explain which date and exchange-rate source applies to the sale, refund, platform fee, payout, month-end monetary balance, and intercompany item. One monthly average rate applied to every event can conceal realized and unrealized exchange differences, especially when a USD sale settles in EUR and reaches a CNY bank account after a reserve period.
IAS 21 also addresses translation of foreign operations and presentation in a currency different from functional currency. A multi-entity group should test each entity first, then consolidation; translating every store directly into group presentation currency can bypass the legal entity’s books and obscure intercompany or settlement-account differences.
What handover sequence protects reporting continuity?
A controlled handover runs in five stages: freeze scope, collect and index, reconcile opening balances, run parallel close, then transfer primary responsibility. Moving credentials on day one before the old archive is inventoried can stop access to vouchers, filing histories, marketplace reports, or explanation trails needed for the next close.
- Freeze: list every entity, store, bank, payment account, warehouse, filing, system, and reporting deadline.
- Collect: receive ledgers, vouchers, reports, source exports, filings, contracts, fixed-asset records, inventory workpapers, and open issues.
- Reconcile: agree bank, tax, receivable, payable, inventory, and equity openings to signed prior-period records.
- Parallel close: run one period with old and new mapping logic, then explain differences rather than selecting the preferred total.
- Transfer: change access, confirm backups, sign the archive inventory, and retain a time-boxed questions channel.
Order No. 98 Article 13 also places duties on the client to provide authentic and complete original documents promptly and correct or supplement rejected documents. A provider switch cannot repair missing commercial records by assumption; management must assign internal owners for sales contracts, platform exports, inventory movement, invoices, and cash evidence.
Which delivery model fits which operating stage?
A basic statutory-bookkeeping model fits a simple entity with one store and low transaction complexity; a reconciliation-led model fits several stores, payment accounts, refunds, and inventory locations; an embedded finance model fits groups needing recurring management reporting, consolidation, financing support, or close governance. The labels describe scope, not a ranking of named firms.
Store count alone should not choose the model. One store with three settlement currencies, bonded inventory, creator commissions, and frequent returns can require more controls than five domestic stores sharing one entity, bank, currency, warehouse, and standard settlement cycle.
| Operating pattern | Minimum scope | Upgrade trigger |
|---|---|---|
| one entity, one store | books, reports, filings, archive | new platform or inventory location |
| multi-store operations | settlement and store-profit bridges | shared costs or payment accounts |
| multi-entity group | entity mapping and intercompany close | consolidation or financing round |
| cross-border group | currency and warehouse controls | new functional currency or FX route |
The purchasing decision should compare the cost of defined deliverables, not monthly price divided only by entity count. Quotes become comparable when they state store count, order volume, currencies, bank accounts, warehouses, close deadline, review level, reporting outputs, and exit package.
Which primary rules support this scorecard?
Three primary sources support the scorecard, checked on 26 August 2026. Ministry of Finance Order No. 98 defines agency-bookkeeping qualification, contract, client, confidentiality, and handover boundaries; Cai Kuai [2024] No. 11 defines data and system controls; IAS 21 defines the foreign-currency concepts used in the trial.
- China Ministry of Finance Order No. 98 — Agency Bookkeeping Measures
- Cai Kuai [2024] No. 11 — Accounting Informatization Work Standards and the official PDF attachment
- IFRS Foundation — IAS 21, The Effects of Changes in Foreign Exchange Rates
- Related: choosing between a bookkeeper, accountant, and CFO
- Related: reconciling sales, fees, holds, and bank receipts
The trial score, dates, points, store examples, currencies, and handover schedule are illustrative buyer controls, not official thresholds, market prices, or service promises. Qualification, filing, archive, and reporting duties should be confirmed for each legal entity and engagement.
Questions operators ask before changing teams
Is a bookkeeping license enough to choose a China ecommerce provider?
No. Order No. 98 makes qualification an entry gate, but a provider should still pass a trial close using store IDs, settlement data, inventory movements, currencies, journals, and tax records. Licensing and ecommerce delivery competence answer different questions.
Should every entity switch on the same day?
Not usually. A staged handover lets the group inventory records, reconcile openings, run one parallel close, and resolve access issues before transferring the next entity. Entities with imminent filings, audits, financing requests, or incomplete archives may need a different sequence.
What is the most important exit clause?
The strongest exit clause is a complete, structured, signed return of accounting data and open issues by entity and period. Order No. 98 requires termination handover to be addressed, while Cai Kuai [2024] No. 11 supports usable outputs, archives, security, and backup controls.