Exhibit 8.1

SUBSIDIARIES OF REGISTRANT

Wholly Owned Subsidiaries:

• DL Education Service, LLC, incorporated in Delaware, the United States of America

• China Distance Education Limited, incorporated in Hong Kong Special Administrative Region

• Practice Enterprises Network China International Links Limited, incorporated in Hong Kong Special Administrative Region

• Beijing Champion Distance Education Technology Co., Ltd., incorporated in the People’s Republic of China

• Beijing Champion Education Technology Co., Ltd., incorporated in the People’s Republic of China

Consolidated Affiliated Entity:

• Beijing Champion Hi-Tech Co., Ltd, incorporated in the People’s Republic of China

• Beijing Caikaowang Company Limited, incorporated in the People’s Republic of China

• Beijing Champion Wangge Education Technology Co., Ltd., incorporated in the People’s Republic of China

• Beijing Zhengbao Yucai Education Technology Co., Ltd., incorporated in the People’s Republic of China

• Beijing Haidian District Champion Training School, incorporated in the People’s Republic of China