I. Introduction

On June 30th 2019, the National Development and Reform Commission and the Ministry of Commerce jointly released the Special Administrative Measures for Foreign Investment Market Access (2019 Version) (Negative List), the Special Administrative Measures for Foreign Investment Market Access in Pilot Free Trade Zones (2019 Version) (FTZ Negative List). The new Negative Lists indicate China’s determination to further liberalize foreign investment by adopting the negative list approach and the pre-establishment nation-al treatment. This note addresses the changes in the new Negative Lists. Part II reviews the development of the negative list approach in both international and domestic contexts. Part III assesses the transparency and predictability of the new Negative Lists from a comparative perspective. Part IV analyses the structural change brought by the new Foreign Investment Law (FIL). Part V discusses the potential dispute settlement mechanism under the current legal framework.