Chinese Outbound Investment Supercharges Cross-Border Legal Services, as Litigation Grows More Frequent and Harder to Predict / 中企出海带火涉外法律服务，跨境诉讼更频更难

Chinese Outbound Investment Supercharges Cross-Border Legal Services, as Litigation Grows More Frequent and Harder to Predict

中企出海带火涉外法律服务，跨境诉讼更频更难

Chinese companies going global is pushing outbound legal services to become one of the fastest-growing segments of Chinese law firms’ practices. Yet as the volume climbs, cross-border disputes are also becoming more frequent and more complex: once litigation becomes entangled with geopolitics, the very segment growing fastest is precisely the one whose risks are hardest to predict.

中企出海，正把中国律所的涉外业务推上增长最快的板块之一。但业务量攀升的同时，跨境争端也在变得更频繁、更复杂：诉讼一旦与地缘政治纠缠，涨得最快的那块业务，恰恰是最难预判风险的。

Over the past two years, Chinese companies’ “going global” has shifted from an option to a necessity, a change that has directly rewritten the demand structure for legal services. In its annual survey published in October 2026, China Business Law Journal (《商法》) aggregated financial data from 128 Chinese law firms, and one signal was clear: outbound legal services are becoming one of the industry’s fastest-growing segments. In the survey, Li Chen, a member of the board of directors of Dacheng’s Shanghai office, described the growth in demand for cross-border legal services as “explosive.” His explanation: geopolitical shifts have pushed Chinese companies to accelerate their deployments into Southeast Asia, the Middle East, and Latin America to hedge risk, driving transactional work such as cross-border investment structuring and overseas investment (ODI) filings, while the compliance pressure on companies already abroad and the expansion of their overseas asset bases have lifted demand for cross-border dispute resolution.

过去两年，中国企业“走出去”从可选项变成必选项，这一转变直接改写了法律服务的需求结构。《商法》在2026年10月发布的年度调研中，汇总了128家中国律所的财务数据，一个信号颇为清晰：涉外法律服务正成为行业里增长最猛的板块之一。调研里，大成上海董事局董事李晨用“井喷”形容跨境法律服务需求的增长；他给出的解释是，地缘政治变化促使中企加速向东南亚、中东、拉美布局避险，带动跨境投资架构设计、境外投资备案等交易类业务，而已出海企业的合规压力、海外资产规模扩大又推高了跨境争议解决需求。

The picture is clearer at the geographic level. The same survey shows that among enterprises’ demand for overseas legal services, Hong Kong accounts for 7.3%, the United States 6.5%, and Indonesia 4.7%, leading the field; by region, Southeast Asia, at 19.4%, is the most favored outbound destination, followed by Western Europe at 11.8% and Hong Kong, Macao, and Taiwan at 10.1%. The frenzy on the demand side soon transmitted to the supply side: from July 2025 to June 2026, Southeast Asia (27%) was the most favored location for Chinese law firms to open new offices, with Europe (20%) next, as London, Italy, and Hungary all welcomed the establishment of Chinese firms. The trend is even more visible in Belt and Road Initiative (BRI) projects: in 2025, the value of newly signed overseas contracted engineering projects reached US$289 billion, up 8.2% year on year to a record high, with 89.2% concentrated in partner countries; alongside it rose demand for FIDIC-contract application, responses to overseas compliance reviews, and cross-border arbitration.

更具体的落点是地域。同一份调研显示，企业对海外法律服务的需求中，中国香港占7.3%、美国6.5%、印尼4.7%位居前列；按地理区域看，东南亚以19.4%成为最受欢迎的出海目的地，西欧11.8%、中国港澳台10.1%紧随其后。需求侧的火爆，很快传导到供给侧：2025年7月至2026年6月，东南亚（27%）是中国律所新设办公室最青睐的地点，欧洲（20%）次之，伦敦、意大利、匈牙利纷纷迎来中资律所落子。在“一带一路”工程上，这一趋势更为直观：2025年中国境外承包工程新签合同额达2890亿美元，同比增长8.2%，创历史新高，其中89.2%集中于共建国家；随之上升的，是适用FIDIC合同、应对境外合规审查、处理跨境仲裁的需求。

The growth in cross-border legal services is no longer driven by any single stage of work alone, but by the entire chain heating up together, from front-end to back-end. In the China Business Law Journal survey, Li Chen of Dacheng Law Offices summarized this demand as a “full chain” — front-end structuring during the “going out” phase, mid-stage compliance operations during the “moving in” phase, and back-end dispute resolution during the “coming out” phase. “Outbound investment has shifted from an ‘option’ to a ‘necessity,'” he said, and the legal services it spawns cover the full life cycle. Previously these three stages belonged to different teams and different windows; now they are triggered in sequence by the same group of outbound companies, turning legal services from point consultations into comprehensive, full-life-cycle needs.

跨境法律服务的增长不再由某一段业务单独拉动，而是从前端到后端的整条链条一起升温。大成律师事务所的李晨在《商法》调研中将这条需求概括为“全链条”——企业“走出去”阶段的前端架构设计、“走进去”阶段的中期合规运营、“走出来”阶段的后端争议解决。“企业出海已从‘可选项’变为‘必选项’，”他说，由此衍生的法律服务覆盖全周期。过去这三段分属不同团队、不同窗口，现在被同一批出海企业连续触发，法律服务从单点咨询变成覆盖全周期的综合需求。

The fastest-growing parts are precisely the latter two stages. Geopolitical shifts have pushed Chinese companies to accelerate risk-hedging deployments in Southeast Asia, the Middle East, and Latin America, driving transactional work such as cross-border investment structuring and overseas direct investment (ODI) filings; compliance pressures on companies already abroad — export controls, ESG, cross-border data flows — keep rising; and the expansion of overseas asset bases lifts demand for cross-border dispute resolution. In hot regions such as Southeast Asia and the Middle East, local legal markets remain immature, so Chinese companies increasingly rely on Chinese law firms to coordinate multi-jurisdiction teams and deliver full-life-cycle integrated services. This has created new service models and revenue growth for China’s leading firms, and shifted competition among firms from “who has an overseas signboard” to “who can connect multiple jurisdictions.”

增长最快的恰是后两段。地缘政治变化促使中企加速向东南亚、中东、拉美避险布局，带动跨境投资架构设计与境外投资（ODI）备案等交易类业务；已出海企业的出口管制、ESG、数据跨境等合规压力持续上升；海外资产规模扩大又推高跨境争议解决需求。东南亚、中东等热点区域本地法律市场尚不成熟，中企越发依赖中国律所统筹多法域团队提供覆盖全周期的综合服务——这为中国头部律所创造了新的服务模式与业务增量，也把律所的竞争从“谁有海外招牌”推向“谁能打通多法域”。

In response, Chinese law firms are moving first on the supply side. On October 26, 2026, Zhejiang Taihang Law Firm established the Taihang Vietnam International Cooperation Liaison Center; it already operates more than 30 branch offices in Beijing, New York, and elsewhere, and has built “LexPort,” a cross-border trade and investment legal services platform, in Hong Kong. Along the same lines, Shanghai’s Huangpu District has pushed firms including Hanhong, Bang & Xinyang, Tianchi Juntai, Jin Mao, and Jianwei to set up branches in Indonesia, Hong Kong, and Laos, respectively, and the Huangpu District Lawyers Working Committee signed memoranda of cooperation with the Law Society of Singapore and the Malaysian Bar. The supply-side footprint corroborates the survey’s figures on new offices — “Southeast Asia 27%, Europe 20%”: wherever demand goes, Chinese law firms lay down their networks.

与之对应，中国律所正在供给侧抢先落子。2026年10月26日，浙江泰杭律师事务所成立泰杭越南国际合作联络中心，其在北京、纽约等地已设30余家分支机构，并在中国香港建设“法海网LexPort”跨境贸易投资法律服务平台。同一方向上，上海黄浦区推动翰鸿、邦信阳、天驰君泰、金茂、建纬等律所分别在印尼、中国香港、老挝设立分支机构，黄浦律工委与新加坡、马来西亚律师公会签署合作备忘录。供给侧的布局，与调研里“东南亚27%、欧洲20%”的新设办公室数据彼此印证：需求往哪里走，中国律所的网点就往哪里铺。

As volume rises, cross-border litigation is increasingly intertwining with geopolitics — a second layer of risk behind the growing market. A report released by Quinn Emanuel Urquhart & Sullivan in October specifically noted that the disclosure obligations of U.S.-listed Chinese companies are increasingly intersecting with geopolitical factors. Quinn Emanuel is a well-known international firm focused on commercial litigation and arbitration, and its assessment is telling of the structural shift in cross-border disputes.

业务量上升的同时，跨境诉讼正越来越多地与地缘政治交织，这是增量市场背面的另一重风险。美国昆鹰律师事务所10月发布的报告特别指出，中概股企业的信息披露义务正越来越多地与地缘政治因素相互交汇。昆鹰律师事务所是专注商事诉讼与仲裁的知名国际律所，其判断足以反映跨境争端的结构变化。

A concrete example is Alibaba. In August 2026, Alibaba faced a securities class action in the United States, accused of misleading investors on two fronts: first, its AI-related activities, and second, the risk that its inclusion by the U.S. Department of Defense on a “Chinese military companies list” could pose to its share price. Companies whose place of listing and place of regulation sit in two different countries are bringing the variables of geostrategic competition straight into the courtroom. The same logic applies to DJI: as Caixin reported, DJI was added by the U.S. Department of Defense in October 2022 to its so-called “list of Chinese military-industrial companies,” filed suit in October 2024 in the U.S. District Court for the District of Columbia, and after its dismissal in September 2025 appealed — a single list was enough to set off a cross-year cross-border lawsuit.

一个具体样本是阿里巴巴。2026年8月，阿里巴巴在美国遭遇证券集体诉讼，被指控在两方面误导投资者：一是公司的人工智能相关活动，二是美国国防部将其列入“中国军事企业清单”可能对其股价造成的风险。上市地与监管地分处两国的企业，正把地缘博弈的变量直接带进法庭。同样的逻辑也落在大疆身上：财新报道提及，大疆2022年10月被美国国防部列入所谓“中国涉军工企业清单”，2024年10月向美国哥伦比亚特区联邦地区法院提起诉讼，2025年9月被驳回后提出上诉——一份清单，足以牵出跨年的跨境诉讼。

Western legal media have also recorded the same turn. In October 2026, Legal360 Pulse reported that directors of Super Micro Computer were hit with a shareholder derivative lawsuit accusing them of funneling AI technology to Chinese companies, violating export controls, and misleading investors; that same month, bipartisan U.S. lawmakers introduced a bill that would restrict certain Chinese companies from obtaining and enforcing U.S. patents. That cross-border litigation is being complicated by geopolitics has become a consensus view.

西方法律媒体也记录到同一转向。Legal360 Pulse 在2026年10月报道，超微电脑（Super Micro）的董事被股东提起衍生诉讼，指控其向中国公司输送人工智能技术、违反出口管制并误导投资者；同月，美国国会两党议员提出法案，拟限制特定中国公司取得与执行美国专利。跨境诉讼因地缘政治而复杂化已成共识。

Facing such multi-jurisdiction disputes, Chinese lawyers are shifting their focus upstream. At an October 21, 2026 press conference held by the State Council Information Office, Liu Xiangwen of Zhong Lun Law Firm, drawing on more than 20 years of cross-border litigation practice, noted that Chinese companies going global often involve different countries, multiple judicial procedures, and multiple law firms; if each side speaks its own language and manages only its own piece, the company ends up passive. In his view, the outbound lawyer should act as “general coordinator,” orchestrating domestic and foreign lawyers to ensure consistency in legal positions, factual narratives, and evidentiary logic across the courts and arbitral tribunals of different countries. According to him, his team has helped more than 100 Chinese companies build domestic-and-overseas compliance and risk-control systems. Chinese lawyers do not give independent opinions on foreign law; instead, they cite the legal opinions issued by locally licensed lawyers in the target jurisdiction and then integrate and vet the conflict-of-laws issues — this “cite-and-integrate model” is designed precisely to prevent and control risk upstream in cross-border disputes.

面对这类跨法域争端，中国律师的重心正在前移。2026年10月21日国新办记者见面会上，中伦律师事务所刘相文结合20余年跨境诉讼实务提到，中国企业出海往往涉及不同国家、多套司法程序、多家律所，若各说各话、各管一段，企业会陷入被动；他认为涉外律师应做“总协调”，统筹协调境内外律师，确保不同国家法庭、仲裁庭的法律立场、事实陈述、证据逻辑一致。据其介绍，团队已帮助100多家中国企业搭建境内外合规风控体系。中国律师不就外国法发表独立意见，而是转引目标国执业律师出具的法律意见，转而整合与把关冲突法问题——这套“转引模式”正是为跨境争端前置防控风险而设。

Faced with complex disputes running in parallel across multiple jurisdictions and procedures, Chinese law firms’ answer is to replace lone-soldier operations with “fighting as a coordinated group.” In the aforementioned China Business Law Journal survey, Wang Shu of Han Kun Law Firm pointed out that the key to cross-jurisdiction coordination lies in combining a genuinely international partner team with local execution capability; confronting complex disputes across multiple procedures and jurisdictions, one must coordinate lawyers of different professional backgrounds to provide an integrated solution from analysis to execution. This is not simply piling people together, but twisting lawyers scattered across domestic and overseas offices and different practice lines into a single chain capable of coordinated action.

面对多法域并行、多程序同跑的复杂争议，中国律所给出的解法是“集团化作战”替代单兵作战。前述《商法》调研中，汉坤律师事务所王舒提到，跨法域联动的关键在于真正国际化的合伙人队伍与本土落地能力结合；面对多程序、多法域并行的复杂争议，须统筹不同专业背景的律师，提供从分析到执行的一体化方案。这不是把人堆在一起，而是把分散在境内外、不同专业条线的律师拧成一条能够协同作战的链条。

This approach already has domestic implementation examples. When Jingshi Law Firm attended the Hainan Free Trade Port Legal Week in October 2026, Li Hao, director of its Central Asia regional center, observed that Chinese companies’ outbound investment has moved from single-project deployment to the systematic going-global of industrial and supply chains, and that the focus of legal services has shifted from ex-post relief to ex-ante planning and full-process accompaniment; he argued that the legal risk of cross-border investment is essentially a collision of the institutional environments, governance cultures, and regulatory logics of different jurisdictions, and that only by building governance structures and compliance systems matched to the investment destination can a company steadily cross from “going out” to “settling in.” From the “fighting as a coordinated group” in the surveys to the “full-process accompaniment” in practice, Chinese law firms’ support for Chinese companies going global is evolving from order-taking, point services to life-cycle-spanning coordination.

这套做法在国内已有落地样本。京师律师事务所2026年10月出席海南自由贸易港法律周时，其中亚区域中心主任李豪提到，中资企业对外投资已从单点项目布局迈向产业链、供应链的系统性出海，法律服务的重心由事后救济前移至事前规划与全程陪伴；他认为跨境投资的法律风险本质是不同法域制度环境、治理文化与监管逻辑的碰撞，唯有建立与投资目的地相匹配的治理结构与合规体系，方能从“走出去”稳健跨越到“落下来”。从调研里的“集团化作战”，到实务中的“全程陪伴”，中国律所对中企出海的支撑，正从接单式的单点服务走向贯穿全周期的协同。

The revenue data from China Business Law Journal, Caixin’s observations on cross-border litigation, and Legal360 Pulse’s Western perspective all point in the same direction: cross-border legal services are heating up, and the geopolitical risks entwined with them are deepening. That outbound investment has put outbound legal services on a fast-growth track is already visible from firms’ revenue structures to their overseas footprints. But going global brings more than just business growth: when litigation entangles with geopolitics, when the place of listing and the place of regulation sit in two different countries, the very structure of disputes is growing more complex. Growth and risk arriving together — that is the real reckoning this round of outbound legal services must get right.

《商法》的营收数据、财新的跨境诉讼观察与 Legal360 Pulse 的西方视角，指向同一个方向：跨境法律服务在升温，缠绕其上的地缘风险也在加深。中企出海把涉外法律服务推上增长快车道，这一点从律所营收结构到海外布点都已显现。但出海带来的不只是业务增量：当诉讼与地缘政治纠缠，当上市地与监管地分处两国，争端的结构本身正在变复杂。增长与风险同向而来，才是这一轮出海法律服务真正要算清的一笔账。

If the geographic concentration of Chinese outbound investment keeps tilting toward Southeast Asia and the Middle East, the center of gravity of cross-border legal services will shift further from transactional work to compliance and dispute resolution; if geopolitical penetration of cross-border litigation deepens, whether Chinese law firms can truly twist their domestic and overseas teams into a “fighting as a coordinated group” chain will determine whether they can catch this wave of demand. Judging whether a firm truly stands is not about how many overseas signboards it hangs, but about whether it can maintain consistency in legal positions and evidentiary logic across multiple jurisdictions and procedures.

若中企出海的地域集中度继续向东南亚、中东倾斜，跨境法律服务的重心就会进一步从交易类业务移向合规与争议解决；若地缘政治对跨境诉讼的渗透加深，中国律所能否把境内外团队真正拧成“集团化作战”的链条，将决定其能否接住这一轮需求。判断一家律所是否站得住，看的不是它挂出多少个海外招牌，而是它能否在多个法域、多套程序里保持法律立场与证据逻辑的一致。

Sources: China Business Law Journal (《商法》), report of October 22, 2026; Legal360 Pulse (Law360), October 2026; Caixin, report of October 29, 2026; China Lawyer Network (practice articles on outbound legal services); the State Council Information Office press conference of October 21, 2026; public information from the Shanghai Huangpu District Bureau of Justice / Huangpu District Lawyers Working Committee; public information from Zhejiang Taihang Law Firm; public information from Jingshi Law Firm.

来源：China Business Law Journal《商法》（2026年10月22日报道）；Legal360 Pulse（Law360，2026年10月报道）；财新（2026年10月29日报道）；中国律师网（涉外法律服务实务文章）；国新办（2026年10月21日中外记者见面会）；上海市黄浦区司法局／黄浦律工委公开信息；浙江泰杭律师事务所公开信息；京师律师事务所公开信息。