Geneva · Private Lombard Credit · By Introduction
Asia-Pacific SSE, SZSE CNY

Lombard loans in China.

Private, securities-backed credit against China-listed shares — pledged, not sold, with ownership retained.

A Lombard loan against China-listed shares is credit secured by a pledge of equity listed on the SSE, SZSE. The holder pledges the shares as collateral, draws cash against a fraction of their market value, keeps beneficial ownership and dividends subject to structuring, and recovers the position in full on repayment. It is a loan against shares rather than a sale of them — the Geneva private-banking form of what is elsewhere called a share-backed loan.

Key takeaways
  • Lombard loans are arranged against shares listed on the SSE, SZSE (SSE / SZSE).
  • The pledge is not a sale: ownership, dividends, and the upside stay with the holder.
  • Loan-to-value is calibrated to the specific position, funded in CNY or cross-currency.
  • Structured under the CSRC regime, with disclosure from 5%.

Eligible collateral and venues

Lombard Financing arranges facilities against equity listed on the principal China venues: Shanghai Stock Exchange (SSE); Shenzhen Stock Exchange (SZSE). Eligibility at the position level turns on the liquidity and free float of the specific line, its volatility, and the size of the holding relative to its typical traded volume — the same variables that drive the loan-to-value.

Regulator and disclosure

Shares listed in China are regulated by China Securities Regulatory Commission (CSRC). Substantial-shareholding disclosure is triggered from 5%, and a pledge over a large line is structured with that reporting regime in view so that the transaction remains discreet and compliant. Where a holding sits near a control or takeover threshold, the structure is arranged to avoid disturbing the position.

Funding, custody, and structuring

Facilities are typically arranged for a tenor of twelve to thirty-six months, funded in CNY or in another currency on a cross-currency basis. Throughout the facility the pledged shares are held by a qualified custodian under bankruptcy-remote arrangements, so the security is clean and the holder’s ownership is preserved. Non-recourse, limited-recourse, and full-recourse structures are available, and the choice interacts with the loan-to-value and the pricing. One distinction is worth drawing at the outset: this is not a stock loan in the securities-lending sense, where title passes to a borrower who may on-lend or short the line. Here the shares are pledged and remain the holder’s throughout, as the comparison of Lombard, margin, and stock-loan structures sets out.

Listing venue(s)Shanghai Stock Exchange (SSE); Shenzhen Stock Exchange (SZSE)
RegulatorChina Securities Regulatory Commission (CSRC)
CurrencyCNY (cross-currency available)
Disclosure thresholdFrom 5% substantial-holding disclosure
Principal indicesSSE Composite, SSE 50, STAR 50; SZSE Component Index, ChiNext Price Index
Indicative tenor12–36 months, renewable by agreement
RecourseNon-recourse / limited-recourse / full-recourse

Detail by listing venue

Each venue has a page of its own, setting out how securities-backed credit is arranged against shares admitted there — the disclosure regime, the settlement and custody chain, the eligible segments, and the currency in which a loan against shares is normally drawn.

Considering a Lombard loan against a China-listed position?

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Venues Per-Exchange Detail

The listing venues in China.

Adjacent Markets Same Region

Lombard loans across Asia-Pacific.

In Depth Regulatory & Structuring Detail

On this market, specifically.

The market and its listed universe

Mainland China lists more than five thousand A-share companies across three venues. Shanghai carries the Main Board and the registration-based STAR Market; Shenzhen carries its Main Board, merged with the former SME board in 2021, and ChiNext; and the Beijing Stock Exchange, created in 2021, serves innovative smaller issuers. CSI 300, SSE 50, the SSE Composite, the SZSE Component Index, the ChiNext Index and STAR 50 are the reference points. Two features shape any financing. Ownership is highly concentrated, with SASAC-supervised state parents controlling much of the large-cap tier and identifiable founder-controllers behind most ChiNext and STAR issuers, portions of whose stock may still sit under lock-up. And turnover is retail-driven to a degree unmatched in the region, which makes single-name liquidity unusually sentiment-sensitive.

Who borrows against listed shares here

The archetypal borrower here is the founder-controller of a ChiNext or STAR issuer holding a decisive personal stake, frequently through a family holding company. Alongside sit SASAC-supervised state parents, provincial state investment platforms, and venture and private-equity sponsors emerging from lock-up. Pledging is deeply embedded in this market for a specific reason: rules restricting reduction of holdings by controlling shareholders — tightened again in recent years, including for issuers trading below issue price or below net assets — make outright selling slow, visible and sometimes simply unavailable. Share-backed financing becomes the practical route to funding an unlisted business or a group’s working capital. The 2018 episode remains the standing lesson in what over-pledging into a falling market does.

Disclosure and regulation

Mainland China discloses substantial holdings under Article 63 of the PRC Securities Law: a holder crossing 5% files, refiles on every further 5% band, and observes a short trading freeze in the days following disclosure — a timing point that matters where a Lombard facility might one day need to enforce. The CSRC supervises. The larger structural fact is access: direct A-share ownership by non-residents is restricted, so most international portfolios reach these shares through Stock Connect or the QFII / RQFII channels. We shape any Lombard credit around the access route the client already holds, since that route governs custody, enforcement and repatriation.

The legal form of the security

Security over mainland shares runs through the security-interest provisions of the PRC Civil Code, in force since January 2021, which replaced the former Property Law and Guarantee Law. A pledge of rights over listed equity is created on registration with the depository. Onshore this supports a large intermediated market in exchange-traded stock pledge repo, which the exchanges and the industry association tightened materially after the 2018 unwinding exposed how far controlling shareholders had pledged. Enforcement is court or arbitration led, with realisation by agreed sale or auction rather than self-help, and the Civil Code restricts a pledgee simply keeping the collateral. For a foreign lender the harder question — strictly one for PRC counsel — is what it could lawfully take title to at all.

Custody and how security is taken

A-shares are registered and settled by China Securities Depository and Clearing Corporation, ChinaClear, and the model is directly held: each investor has a real-name securities account at the depository rather than an entitlement traced through layers of nominee. Securities settle same day with cash following. That direct structure also carries the security interest. Under the PRC Civil Code a pledge over shares registered with a securities depository is created when the pledge itself is registered with that depository, so a charge over A-shares is a ChinaClear registration rather than a private contract alone — and aggregate pledge levels are published by the exchanges. Northbound Stock Connect lines sit behind an HKSCC nominee and follow an entirely different chain.

Currency and cross-border considerations

The renminbi is not freely convertible on the capital account. Onshore CNY trades within a band around a daily central parity while offshore CNH trades freely in Hong Kong and elsewhere; the State Administration of Foreign Exchange administers the perimeter. Non-resident access to A-shares runs through Northbound Stock Connect or the Qualified Foreign Investor scheme, which merged the former QFII and RQFII regimes in 2020 after quotas were removed, and each route carries its own conversion and repatriation mechanics. Where onshore assets secure an offshore loan, the cross-border security rules administered by SAFE — the nei bao wai dai framework — are generally understood to require registration and to constrain how proceeds may be used. Confirm the current position with PRC counsel before committing.

Tax questions to put to your adviser

Securities transaction stamp duty is charged on the seller side of an A-share sale and was reduced in August 2023 as a market-support measure. The questions for a tax adviser are whether creating or releasing a pledge is a transfer for those purposes at all, and what an enforcement sale would attract. For a non-resident holding through Stock Connect or the Qualified Foreign Investor scheme, ask about withholding on dividends, about the treatment of capital gains under the exemptions that have been repeatedly extended for those channels, and about treaty access. Where state-held shares or a listed company’s controlling shareholder are involved, the adviser should also be asked what approvals accompany a pledge.

General information only — not tax advice. Treatment turns on your own circumstances and residence, and on law that changes.

An illustrative example

For illustration only: the founder of a ChiNext-listed manufacturer needs capital for an unlisted subsidiary. Selling is barely an option — the reduction-of-holdings rules on controlling shareholders limit both timing and volume, and any sale is disclosed. Onshore, the answer is usually an exchange-traded stock pledge repo arranged through a securities company, with the pledge registered at ChinaClear. Offshore, the structure depends entirely on the access route: a Connect or Qualified Foreign Investor position sits behind a different custody chain, and the security, the enforcement path and the repatriation mechanics all have to be settled with counsel before anything is committed.

Illustrative only — not an offer, a quotation, or a commitment to lend.

FAQ China

Lombard loans in China, answered.

Q · 01Can I borrow against China-listed shares without selling them?
Yes. A Lombard loan against China-listed shares is a pledge, not a sale: you keep beneficial ownership, dividends (subject to structuring), and the upside, and recover the position in full on repayment. Cash is advanced against a fraction of the pledged shares' market value.
Q · 02What loan-to-value is available on China shares?
Loan-to-value is set per position, not per market. Liquidity and free float, volatility, the size of the holding relative to daily volume, single-name concentration, and the recourse profile all drive the figure. Indicative ranges are issued after a review of the specific holding; there is no rate card.
Q · 03Which regulator and disclosure rules apply?
Shares listed in China fall under China Securities Regulatory Commission (CSRC). Substantial-holding disclosure applies from 5%; the pledge and any enforcement are structured with that regime in mind.
Q · 04Can shares held through Northbound Stock Connect be pledged to an offshore lender?
This is the first question to resolve, not the last. Northbound holdings are mainland A-shares reached through a nominee chain into ChinaClear, and the ability to create security over them, and to enforce it, is governed by mainland rules and Connect programme terms rather than by offshore practice. Any workable structure is more likely to involve security over the offshore custody relationship than a domestic pledge registration. The specific line, its custody route and the enforcement path all go to PRC and Hong Kong counsel before it is treated as collateral.
Q · 05How is a pledge over A-shares actually perfected?
By registration with the depository. Under the PRC Civil Code, a pledge of shares registered with a securities depository takes effect when the pledge itself is registered there, so the step that creates the security is an entry at ChinaClear rather than the signing of a document. In practice the registration is made through the securities company or custodian that maintains the account. Because pledge data is reported and aggregated by the exchanges, the existence of the charge is not private — something concentrated holders should factor in.