Exhibit 8.1

List of Subsidiaries and Consolidated Affiliated Entities

As of December 31, 2022, the Company’s subsidiaries and consolidated affiliated entities include the following entities:

		Place of	Percentage
	Date of	incorporation	of
	incorporation	(or establishment)	ownership
Name	or acquisition	/operation	%		Principal activity
Subsidiaries
Ambow Education Inc.	July 5, 2016	United States	100	%	Investment Holding
Ambow BSC Inc.	February 14, 2017	United States	100	%	Investment Holding
Bay State College Inc.	November 20, 2017	United States	100	%	CP&CE Programs
Ambow NSAD Inc.	May 8, 2019	United States	100	%	Investment Holding
NewSchool of Architecture and Design, LLC (“NewSchool”)	March 6, 2020	United States	100	%	CP&CE Programs