This paper provides a framework for comparing project management based delivery systems in the current American, British, Finnish and Chinese construction markets. Nowadays, the framework of Chinese project management based delivery systems is being preliminarily established in accordance with the new policy, namely the "Guidance Opinions on the Fostering and Development of Enterprises for General Project Contracting and Project Management" (hereinafter called "Guidance Opinions"), which was enacted in 2003 by the Ministry of Construction. The comparisons include classification, definition, contractual relationships, roles and responsibilities, risk allocation and reimbursement for different project management based delivery methods. The development status of construction project management stays at different level in US, UK, Finland and China. Subsequently a possible development direction of project management. based delivery systems (i.e. consulting CM and contracting CM) are presented as reference for the relevant policyrnakers and construction contracting professionals in China's construction industry. In the end, the paper analyzes the facing barriers and problems that are incurred from the current construction regulatory systems, and then gives the pertinent suggestions.