On November 3, 2026, the China National Intellectual Property Administration (CNIPA) issued the Plan for Patent and Trademark Examination in the 15th Five-Year Period (the "Plan"). It sets examination priorities through 2030: clearer rules for AI, big data and gene technology; AI-assisted examination; and a tougher stance on deceptive and bad-faith trademarks. For foreign applicants, the most immediate consequences fall on trademark portfolios, ahead of the revised PRC Trademark Law taking effect on January 1, 2027.

• Patents: CNIPA will refine examination standards for big data, AI and gene technology, and will study standards for biological breeding and green, low-carbon technologies. Applications with a concrete technical problem and demonstrable effect should fare better than broadly worded filings.

• AI in examination: The Plan creates an "AI+" examination project and plans wider use of multimodal large models across the examination workflow.

• Trademarks: CNIPA will invalidate registered deceptive marks on its own motion, implement ex officio revocation of marks used in a misleading way, and look through applicants and agencies behind bad-faith filings.

• Timing: The revised Trademark Law, adopted on June 26, 2026, takes effect on January 1, 2027. Portfolio reviews should happen before then.

• International alignment: The Plan calls for closer links with the CPTPP and other high-standard trade rules, and for a larger role for the IP5 offices and BRICS cooperation mechanisms in shaping international examination rules.

This alert is based on CNIPA's published summary of the Plan and official and state-media coverage. We have not relied on the full text. The Plan does not address foreign applicants specifically, so the implications below reflect our assessment.

The Plan is CNIPA's roadmap for how patents and trademarks will be examined between 2026 and 2030. It rests on five principles: quality first, reform and innovation, service for development, systemic coordination and technology empowerment. By 2030, CNIPA aims to have a "first-class" examination body with world-class standards.

The Plan sets four priorities: patent examination, trademark examination, international cooperation on examination, and examination capacity building. It also establishes seven special projects. Four have been named publicly:

1. Improving rules for patent examination in emerging fields

2. Improving trademark examination quality

3. "AI+" examination

4. Systematic governance of bad-faith trademark applications

The other three have not been itemized in the coverage we have reviewed.

The Plan builds on results from the 14th Five-Year period (2021–2025), as reported by CNIPA:

• Average examination time for invention patents fell from 20 months to 15 months.

• Trademark registration examination held steady at about four months.

• Accuracy exceeded 95% for invention patent examination and reexamination decisions.

• Spot-check pass rates exceeded 97% for trademark examination, opposition and review.

These figures are CNIPA's own, and we have not independently verified them. They suggest the Plan is aimed at consolidating quality, not only speed.

The Plan commits CNIPA to promptly refine examination standards for big data, artificial intelligence and gene technology, and to study improved standards for biological breeding and green, low-carbon technologies. It also calls for improving the examination mechanism for traditional Chinese medicine.

Today, applications in these fields are often examined under general patentability rules. That can produce inconsistent results between examiners. More specific standards should improve predictability. They are also likely to reward applications drafted around a concrete technical problem, with reproducible data and a clear technical effect, and to be less forgiving of speculative or generic disclosure.

The Plan also calls for closer alignment between China's patent legal framework and high-standard international trade rules, including the CPTPP. We would not read this as a commitment to identical rules. It does indicate a direction of convergence with norms that many foreign applicants already use.

The Plan provides for an "AI+" examination project and a management mechanism for it. CNIPA intends to improve its examination and search systems and to expand the use of multimodal large models across examination stages.

In practice, applicants may see shorter pendency and more consistent first-round assessments. Specifications may also be read, at least in part, by automated tools. Clean claim structure, explicit technical effects and well-supported disclosure become more important.

The trademark chapter is where the Plan has the most direct effect on brand owners. It commits CNIPA to:

• refine the examination standard for deceptive marks;

• invalidate registered deceptive marks ex officio, meaning on CNIPA's own motion and without a third-party request;

• implement ex officio revocation of registered marks used in a misleading way;

• strengthen "look-through" supervision of the parties behind trademark applications;

• coordinate governance of trademark agencies that knowingly file bad-faith applications; and

• improve early-warning functions in the examination system.

These measures extend an existing campaign. According to CNIPA, it has rejected about 1.27 million deceptive trademark applications since 2023. As of its April 2026 briefing, it had invalidated 3,351 registered marks on its own initiative under a special program begun in 2025. Reported examples include "Duobandai" (a noodle brand name suggesting a larger quantity) and "Shengdianwang" (suggesting power savings). Applications for "120W" on chargers were rejected as misleading about product function and were not registered.

The risk runs both ways. Squatters will have less room to operate. But a foreign brand whose mark reads as a statement about quality, quantity, function or origin may now be challenged without any third party filing. CNIPA's stated position is that a trademark identifies source and is not an advertising claim.

The revised Trademark Law was adopted on June 26, 2026 and takes effect on January 1, 2027. Provisions relevant to this Plan include:

• an administrative penalty for certain bad-faith applications: a warning and a fine of up to RMB 100,000; and

• refusal of applications that are not filed with intent to use and that clearly exceed reasonable business needs.

The Plan and the revised law reinforce each other. CNIPA's enforcement tools are expanding at the same time as the legal basis for them.

The Plan commits CNIPA to:

• consult on examination topics within the WIPO framework;

• encourage the IP5 offices (China, the United States, the EPO, Japan and Korea) and BRICS cooperation mechanisms to play an important role in forming international examination rules;

• cooperate with Belt and Road countries on examination, information technology and training;

• take part in global governance of intellectual property in the AI field; and

• support Chinese applicants in building overseas patent and trademark portfolios.

For foreign applicants, this suggests Chinese examination rules are more likely to converge with the international mainstream than to diverge from it. Companies active in AI should also watch how Chinese practice influences emerging international standards.

1. Review emerging-technology filings. For AI, biotech, genetics and green-technology matters pending or planned in China, review claim scope and disclosure. Concrete technical problems, supporting data and clear effects are likely to matter more.

2. Raise drafting quality generally. Use clear claim dependencies, explicit technical effects and no unsupported statements.

3. Audit your China trademark portfolio before January 1, 2027. Identify marks that could be read as claims about quality, quantity, function or origin, and consider whether they are at risk of ex officio action.

4. Review filing intent and agent practices. Under the revised law, applications without intent to use may be refused, and agents who knowingly assist bad-faith filings face scrutiny. Confirm that your filing instructions and agent relationships are documented.

5. Align China with your global strategy. If your program is built around US, EU or CPTPP norms, review whether China can be handled within it rather than as a separate track.

What is China's 15th Five-Year Plan for Patent and Trademark Examination? It is a plan issued by CNIPA on November 3, 2026, setting goals, priorities and special projects for patent and trademark examination from 2026 to 2030.

Does the Plan change patent law or trademark law? No. It is an administrative planning document. It does, however, signal how CNIPA will apply and develop examination practice, including alongside the revised Trademark Law effective January 1, 2027.

Will patent examination be faster? The Plan builds on a reduction in invention patent examination time from 20 to 15 months and promises wider use of AI in examination. It does not, in the summaries we reviewed, set a numerical pendency target. We would expect incremental improvement, not a step change.

What is an ex officio trademark invalidation? It is an invalidation decision made by CNIPA on its own initiative, without a request from a third party. Under the Plan, CNIPA will use it against registered marks it considers deceptive.

Can a foreign brand's trademark be invalidated under this campaign? Yes, if CNIPA considers the mark deceptive, for example because it conveys a claim about product quality, quantity, function or origin that misleads the public. The rules apply regardless of the owner's nationality.

What should foreign companies do first? Prioritize a trademark portfolio review before January 1, 2027, then review pending emerging-technology patent filings.