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India’s Press Note 3 Gamble: Opening the FDI Door to China

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Carnegie India

India’s Press Note 3 Gamble: Opening the FDI Door to China

On March 10, 2026, India’s Union Cabinet approved amendments to Press Note 3, a regulation that mandated government approval on all foreign direct investment (FDI) from countries sharing a land border with India. This amendment raises questions primarily about whether its stated benefits will materialize and if the risks have been adequately weighed. This piece will address the same.

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By Konark Bhandari
Published on Apr 28, 2026
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On March 10, 2026, India’s Union Cabinet approved amendments to Press Note 3, a regulation that mandated government approval on all foreign direct investment (FDI) from countries sharing a land border with India. The revised framework now allows investors with non-controlling beneficial ownership of up to 10 percent to invest through the automatic route, where no prior government approval is required at the time of investment, subject to applicable sectoral caps. A sixty-day timeline has also been introduced for processing investment proposals. The official rationale emphasizes greater FDI inflows into start-ups and deep-technology firms, improved ease of doing business, and India’s integration with global supply chains.

The move was in the offing for a while, and was described as a “calibrated” one by India’s commerce minister earlier this year, aimed toward easing norms on investments from China. This amendment to Press Note 3 is not, therefore, a wholesale liberalization. But even calibrated shifts deserve scrutiny, particularly when they involve a country that has expanded its commercial presence in India at an extraordinary pace, all with a negligible investment footprint. Press Note 3, introduced in April 2020 ostensibly to prevent opportunistic takeovers during the pandemic, was always about China. It gained its real force after the deadly Galwan Valley clash of June 2020, the most serious military confrontation between India and China in decades. This eventually led to the banning of over two hundred Chinese mobile applications and a comprehensive chilling of economic ties. This amendment to Press Note 3 raises questions primarily about whether its stated benefits will materialize and if the risks have been adequately weighed. This piece will address the same.

What Drove the Change?

The intellectual scaffolding for this decision was erected well before India’s Union Cabinet met. The 2023–2024 Economic Survey made a pointed argument that there were two ways India could benefit from the “China plus one” strategy that global companies were adopting: (i) integrating into China’s supply chain through trade, or (ii) attracting FDI from Chinese firms. The Economic Survey favored the latter, reasoning that Chinese companies investing in India and exporting to Western markets would generate more domestic value addition than the prevailing pattern of importing intermediates from China with minimal transformation.

Subsequently, a member of the prime minister’s Economic Advisory Council endorsed this logic publicly, noting that China is already India’s largest source of imports and “we cannot wish them away.” The argument gained additional momentum from an uncomfortable reality—despite five years of Press Note 3 restrictions, India’s trade deficit with China ballooned from $85 billion in 2023–2024 to $99.2 billion in 2024–2025, and is estimated to have surpassed $116 billion in calendar year 2025. Chinese FDI, by contrast, amounts to a trivial $2.51 billion, or 0.32 percent of India’s cumulative equity inflows since 2000. The Press Note 3 restrictions, in other words, succeeded in keeping Chinese capital out but did nothing to arrest the flood of Chinese goods inwards.

The diplomatic context also shifted. The October 2024 disengagement agreement at the Line of Actual Control, followed by the Narendra Modi-Xi Jinping meeting in Kazan, created space for economic recalibration. Bilateral trade reached a record 155.6 billion dollars in 2025, making China India’s second-largest trading partner. This headline figure, however, masks a profoundly lopsided relationship where Indian exports remain concentrated in raw materials (notwithstanding the recent surge of electronic exports to China) and lower-value products, while Chinese exports consist overwhelmingly of finished goods and high-value intermediates. Meanwhile, the inter-ministerial approval process under Press Note 3 had become notoriously slow, with proposals sometimes languishing for over a year. Global funds with even tangential Chinese beneficial ownership found themselves caught in bureaucratic limbo. The practical argument for reform was genuine. The system was deterring not just Chinese capital but also legitimate global investment.

The Assumptions Behind the Rationale

The government’s case for liberalizing Press Note 3 rests on several interlocking assumptions, each of which warrants further examination.

The first is that easing restrictions on minority, non-controlling Chinese stakes will unlock meaningful capital inflows from global funds into Indian start-ups and deep-technology firms. This is plausible in a narrow sense. Private equity and venture capital funds, often structured through Singapore and other jurisdictions, frequently have limited partners or co-investors with Chinese beneficial ownership. Press Note 3’s earlier reticence to define beneficial ownership thresholds created genuine ambiguity, and the newly announced 10 percent automatic route threshold will help address this. But whether this will translate into a surge of transformative capital is less certain. The bottleneck for deep-tech investment in India has rarely been due to the regulatory scrutiny of Chinese-linked funds, which even prior to the introduction of Press Note 3 had been content to invest largely in e-commerce companies (as per a study, eighteen of the thirty Indian unicorns in 2020, largely in e-commerce, had a Chinese investor); it has been the lack of depth of the investable ecosystem itself.

The second assumption is that Chinese FDI will bring technology transfer, domestic value addition, and integration into global value chains. This assumption has its limits. Vietnam, often cited in the Economic Survey of 2023–2024 as the model for doing more with China, did not attract huge Chinese investment in high-tech industries, and investments were made as a part of de-risking from China, rather than to build Vietnam’s industrial capacity. A Bank for International Settlements study cited in the Economic Survey for 2023–2024 itself acknowledges that the rise in trade through Vietnam and Mexico is substantially a result of Chinese firms re-routing their supply chains through these countries.

The evidence that Chinese firms willingly transfer proprietary technology to host-country competitors is also thin. Look no further than China’s attempts to stymie the export of specialized equipment to India for electric vehicles and iPhones as recently as last year. What has changed since that led Indian policymakers to assume that any technology transferred to India would not be arbitrarily constricted or withdrawn?

A recent Wall Street Journal report highlighted how China insists on pursuing technological dominance at all costs, even refusing to “cede significant ground in lower-value manufacturing to less developed economies, even as it gains expertise in making cars, aircraft, chips and other high-value goods.” Here, China’s own industrial policy, from Made in China 2025 to its dominance in rare earth processing and battery chemistry, reflects the “ambition to control entire supply chains.” Sure, access to cutting-edge battery technology as a condition of investment, for one, would be very helpful—a page from China’s own playbook of technology transfer. But is it likely to happen, given China’s reluctance to engage in the same?

The third assumption is that this move will not exacerbate the massive India–China trade deficit. Here, skepticism is warranted. India’s import bill from China is anchored in electronics, machinery, organic chemicals, and materials that are “difficult to substitute quickly.” Nearly 80 percent of India’s imports from China are concentrated in just four product groups: electronics ($38 billion in the first ten months of 2025 alone), machinery ($26 billion), organic chemicals ($12 billion), and plastics ($6 billion). These are not discretionary consumer goods; they are the key drivers of Indian manufacturing. If Chinese FDI flows into sectors that assemble products from Chinese-sourced components, as the Production Linked Incentive (PLI) scheme–driven electronics ecosystem already does, the net effect may be to lock in rather than reduce import dependence.

The Information Rights Problem

A feature of the amended rules that has received insufficient attention is the information architecture of minority investment. Investors with non-controlling beneficial ownership of up to 10 percent under the automatic route will, in many corporate structures, gain access to board observer seats, information rights, and influence over strategic decisions disproportionate to their equity stake. This is the standard playbook of venture capital and growth equity. Sometimes, even passive information rights can yield significant intelligence value. The distinction between “non-strategic, non-controlling” interests and genuinely passive capital may not be as clean as the revised amendment announcement to Press Note 3 would like.

This concern is sharpened by the state of Chinese capital markets. Chinese equities have traded below historical valuations for an extended period, and Chinese investors are actively seeking returns outside the mainland.1 India’s technology ecosystem, with its potential for growth, is a natural destination. The question, in addition to how much patient Chinese capital will arrive, is whether India’s regulatory infrastructure can distinguish between capital that creates genuine value and capital that is strategically positioned to extract information.

The Trusted Supply Chain Paradox

The geopolitical implications of the amendment extend well beyond the bilateral relationship. The United States has been constructing an increasingly elaborate architecture of investment screening, centered on the Committee on Foreign Investment in the United States (CFIUS) and now supplemented by outbound investment controls. The America First Investment Policy of February 2025 explicitly identifies China as a foreign adversary and directs CFIUS to intensify scrutiny of investments with Chinese connections. The newly proposed Known Investor Program would exclude investors with significant ties to Chinese supply chains, investors, or operations, even where those ties are otherwise permissible under U.S. law.

India positions itself as a “China plus one” alternative, a destination for companies seeking to diversify away from China. If Chinese capital and components are embedded throughout the Indian industrial base, the value proposition of “China plus one” begins to look uncomfortably flimsy.

India’s decision to relax Chinese FDI restrictions arrives at a moment when Washington is moving in the opposite direction. The implications for Indian firms embedded in global supply chains are not trivial. An Indian semiconductor packaging company or AI startup that accepts Chinese minority investment may find itself flagged by the CFIUS if it subsequently seeks U.S. partnerships or acquisitions. The law’s illustrative list of national security risk factors is deliberately non-exhaustive, and CFIUS priority areas, cybersecurity, critical communications, and ports, all overlap significantly with the sectors where Chinese investment interest is highest.

The phenomenon of “Singapore washing,” whereby Chinese capital is routed through Singaporean entities to obscure its origin, adds a further layer of complexity. The amended Press Note 3 relies on identifying beneficial ownership at the 10 percent threshold. But in the layered fund structures that often characterize venture capital, tracing ultimate beneficial ownership is a challenging exercise in forensic accounting. If the relaxation enables a flow of capital whose Chinese origins are obscured by intermediary jurisdictions, the consequences for India’s positioning in trusted supply chain frameworks could be significant.

The irony here is certainly not lost: India positions itself as a “China plus one” alternative, a destination for companies seeking to diversify away from China. If Chinese capital and components are embedded throughout the Indian industrial base, the value proposition of “China plus one” begins to look uncomfortably flimsy. Further, Washington has already demonstrated leverage over Indian economic decisions, as it did over Indian purchases of Russian oil. The argument that Indian technology products incorporate Chinese-origin components, potentially even derived from misappropriated U.S. intellectual property, is one that could surface in future trade negotiations. The U.S. government’s recent Section 232 investigation into the semiconductor sector was to locate potential security risks in semiconductors or any derivative equipment, on account of their being sourced in significant numbers. Projects that depend on Chinese suppliers should be mindful of the potential negative gaze of the United States and build appropriate strategies for that contingency. Despite all this, India will likely not allow the United States to condition its economic choices.

Irony at the World Trade Organization

Increasing China’s market access in India highlights yet another paradox—China’s challenge to India’s industrial policies at the World Trade Organization (WTO). In October 2025, Beijing filed a dispute against India’s PLI schemes for advanced chemistry cell batteries, automobiles, and electric vehicles, alleging that domestic value addition requirements discriminate against Chinese products under the Agreement on Subsidies and Countervailing Measures, General Agreement on Tariffs and Trade (GATT), and the Trade Related Investment Measures (TRIMs) Agreement. A WTO dispute panel was established in February 2026 after unsuccessful bilateral consultations.

The irony is double-edged. The PLI schemes that China is challenging at the WTO are the very policies that have driven the surge in Chinese imports, because Indian manufacturers assembling under PLI incentives rely heavily on Chinese-sourced components. And it is precisely the logic of building domestic manufacturing capacity, which the PLI schemes embody, that the Economic Survey of 2023–2024 cited as the rationale for courting Chinese FDI. India is looking to invite Chinese capital to build supply chain resilience while simultaneously defending the industrial policies designed to achieve exactly that resilience. It should also be noted that China built its own industry through similar subsidies and industrial policies, and India’s efforts here are not quite of the same scale.  

What Would Success Actually Look Like?

If the government’s rationale plays out the way it hopes, the test of success would not simply be whether FDI inflows from land-border countries (such as China) increase. It would be whether the quality and structure of those inflows contribute to the stated goals—technology absorption, domestic value addition, integration with global supply chains, and reduced import dependence. By these metrics, the historical record of Chinese technology cooperation with developing economies, particularly through vehicles like the Digital Silk Road, offers limited encouragement. Recipients have more often found themselves locked into Chinese tech ecosystems than empowered to build domestic capacity. The argument that imports are surging anyway, and so India might as well join the China-led Regional Comprehensive Economic Partnership (RCEP) or invite Chinese capital, carries a surface plausibility. But it conflates the inevitability of trade dependence with the desirability of investment dependence, which are two very different propositions.

There is also the question of what the amendment does for China. Chinese stock markets have been trading below historical valuations, and Chinese venture capital, not to mention Chinese Big Tech, is under stress from domestic regulatory crackdowns. India’s technology ecosystem offers an attractive destination. But the primary beneficiary may be Chinese capital seeking returns and information rather than Indian firms seeking technology and growth.

The more honest framing is that this is a pragmatic concession to reality. China is inextricable from global manufacturing; restrictions were not working as intended, and the diplomatic space to adjust was open. But this pragmatic concession is seemingly being couched as strategic intent. The gap between “unlocking greater FDI inflows” and actually achieving technology absorption is vast, and India’s institutional capacity to monitor, condition, and enforce meaningful commitments from incoming Chinese investors, where it will have to scrutinize the convoluted nature of such investment structures as well, remains untested.

Conclusion

It remains to be seen how the amendment to Press Note 3 will play out. The 10 percent automatic route threshold is modest, the sixty-day processing timeline introduces accountability, and the recognition that ambiguous beneficial ownership rules were deterring legitimate global investment is overdue. The key challenge is implementation. It is possible that these changes will unlock global capital to India that was held back earlier due to minimal Chinese exposure.

India’s China policy has always been a balancing act, and this amendment was India’s latest move. Whether it represents a step toward equilibrium will be seen over the coming year.

About the Author

Konark Bhandari

Fellow, Technology and Society Program

Konark Bhandari is a fellow with Carnegie India.

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