Source: Zhongbao Xinzh
Over the past period, online marketing for financial products has faced intensified regulatory compliance rectification. Leading social media platforms such as Douyin and Xiaohongshu have launched special self-inspections and remediation initiatives for financial marketing.
On 9 month 15 day, Xiaohongshu released its first "Community Financial Ecosystem Code of Conduct," establishing eight prohibited lines to crack down on fake investor personas, indirect off-platform traffic diversion, and illegal financial activities. The following day, Douyin issued an announcement on further deepening the governance of its financial ecosystem, tightening qualification certification standards, revoking certifications for 6888 "financial advisors," and launching targeted campaigns against cross-border marketing violations, opportunistic trend-chasing for traffic, and illegal stock recommendations or forex trading.
As a key component of the financial online marketing ecosystem, compliance governance for internet insurance is advancing in parallel. According to media reports, regulators are seeking internal feedback on a draft notice titled "Further Regulating Internet Insurance Operations." The document establishes a negative list centered on "Ten Prohibitions," covering the entire business chain—from product design and online marketing to automatic billing and renewal services.
On the eve of National Day, at a critical juncture for industry transformation, insurance institutions, internet traffic platforms, and financial marketing IP entities must all look beyond policy appearances to understand the underlying logic of this stringent regulatory crackdown.
PART
01
From top social media to internet insurance
Will strict regulations target new rules for online financial sales?
The crackdown on financial content across major social platforms and the tightening of regulations in internet insurance are seemingly separate events but share a common root: the "Measures for Online Marketing of Financial Products" (hereinafter referred to as the "Measures"), which will officially take effect on 9/30.
In 4 this year, eight departments including the People's Bank of China, the National Financial Regulatory Administration, and the Cyberspace Administration issued the "Measures," bringing online marketing activities for various financial products—such as deposits, loans, asset management products, and insurance—under a unified regulatory framework. This breaks away from the previous fragmented, sector-specific regulatory approach. The new rules establish clear regulatory red lines across multiple dimensions, including business qualifications, marketing content, marketing practices, and cooperation standards.
Under this unified and comprehensive regulatory framework, major third-party internet platforms have recently accelerated compliance rectifications in the online financial sales sector. These efforts include investigating illegal financial activities, mass removal of non-compliant marketing content and unqualified accounts, and revoking certifications for financial practitioners who fail to meet requirements.
Similarly, amidst the implementation window for the new financial online sales regulations under "9·30", the recent draft proposals issued by the National Financial Regulatory Administration regarding internet insurance operations can be seen as a supporting extension within this specific sector. By addressing prominent issues such as misleading traffic generation, unauthorized deductions, and channel irregularities in internet insurance, these measures ensure seamless alignment between general regulatory rules and industry-specific governance.
Zhongbao Xinzhhi notes that, in the Q&A with responsible officials of the "Measures," regulators also specifically mentioned that subsequent financial regulatory authorities may issue separate network marketing supervision requirements for their respective sub-sectors' financial products. Prior to the formal implementation of the "Measures," financial institutions and third-party internet platforms should proactively accelerate rectification and cleanup of marketing content and practices inconsistent with the "Measures" requirements.
PART
02
Align with Core Guidelines
Internet insurance regulation remains strictly enforced with no relaxation.
Zhongbao New Insights observes that, unlike the general Financial Internet Marketing Measures, this draft regulation on internet insurance operations tightens regulatory oversight and refines compliance standards by aligning with top-level rules while accounting for industry-specific characteristics.
For instance, regarding marketing activities, Article 14 of the Measures stipulates that online marketing must not interfere with others' normal use of the internet and mobile devices. Online marketing conducted via pop-up ads must clearly display a close button and provide a one-click disable function.
Building on this general principle, the draft for public consultation on internet insurance operations has strengthened constraints by explicitly prohibiting "traffic hijacking" and "offline QR code scanning without user demand." These regulatory bans precisely target the long-standing chaos of insurance pop-ups embedded in offline scenarios such as shared power banks, express delivery lockers, and parking payment terminals. Unlike the principle-based requirements of the Measures, the draft uses absolute prohibitive language to eliminate loopholes for non-compliant traffic diversion, resulting in stricter regulatory oversight and enhanced enforceability.
Regarding product management, the draft for public consultation establishes three strict red lines: 1) Do not use unregistered terms and rates; 2) Do not develop products with diminished coverage or distorted features; 3) Do not adjust pricing in disguise or induce sales through product upgrades.
This aligns with the core provisions of Articles 8 and 10 of the Measures, which stipulate: - Online marketing content must be based on financial product contracts. Key information such as interest rates, fees, product categories, and risk disclosures must fully match the corresponding contract terms, with no material omissions, deliberate concealment, or misleading statements. - Exaggerating insurance coverage or product returns is prohibited. Financial products like deposits or asset management products must not be used in simplistic comparisons to insurance returns. - Inducive language such as "low-risk," "low threshold," "high returns," or "no cost" is not allowed.
The above content also aligns with Article 13 of the Measures: when using algorithmic recommendations for marketing, platforms must not deploy models that induce financial consumers to overspend. Historically, chaotic practices in online insurance marketing have frequently featured "low-price traffic generation followed by upselling," which essentially misleads consumers away from their initial coverage needs by highlighting only low-entry barriers.
Notably, automatic and hidden charges have long been the core pain point in consumer complaints about online insurance【Download Black Cat Complaints Client】. In response, the draft solicitation of comments has issued a clear ban: "Do not conceal important information related to charges, do not conduct non-perceptible deductions, and do not perform automatic deductions without explicit authorization."
This corresponds to Article 8 of the Measures, which states: Key information must be displayed clearly and prominently, without omissions, concealment, or misleading content. The draft regulation goes further by specifically addressing industry issues such as "low introductory pricing of 1 yuan in the first month followed by silent automatic renewal charges" and the deceptive practice of "free insurance trials quietly converting into long-term auto-renewal policies," thereby safeguarding consumers' right to know and their right to choose.
Similarly, the draft for public consultation requires that insurance institutions shall not engage unqualified entities in insurance marketing, allow third parties to overstep their authority into core sales processes, or subcontract marketing business layer by layer; they must solidify their own operational responsibilities. This requirement aligns closely with the core regulatory logic outlined in Chapter IV of the Measures.
The Measures explicitly state that financial institutions cannot exempt themselves from their responsibilities for financial products merely because they engage third-party internet platforms to provide online marketing services. Third-party internet platforms must adhere strictly to their role as technology service providers; they are prohibited from engaging in financial business activities in any disguised form or using technical means to help cooperating financial institutions evade regulatory oversight. This also directly aligns with Article 5 of the Measures, which mandates that "third-party internet platforms shall not subcontract or indirectly subcontract entrusted business from financial institutions to other entities," thereby eliminating the root cause of problematic multi-layered subcontracting in the marketing process.
Looking back over an extended period, the compliance rectification for online insurance operations had already been initiated well in advance. On 8 month 7 day, the Beijing Bureau of the National Financial Regulatory Administration issued a special self-inspection notice ahead of others, requiring insurance institutions to conduct a comprehensive review of their marketing accounts across all platforms—including Douyin, Kuaishou, Xiaohongshu, and WeChat Channels. The focus was on eliminating irregularities such as operating without proper qualifications, renting or lending out accounts, making false claims, and illegally directing traffic to offshore insurance products.
With just one day remaining until the implementation of the new "9·30" regulations, a comprehensive financial online sales regulatory framework—featuring full coverage, layered control, and targeted disorder remediation—has now fully taken shape. This progression spans from the issuance of overarching top-level rules, to platform-wide self-inspection and rectification, and finally to tighter internet insurance supervision.
PART
03
Upgrade of Compliance Governance Methodology
The "Five-in-One" approach proves effective
In fact, recent regulatory trends in online insurance have increasingly emphasized stringent oversight. The modern financial regulatory framework—integrating institutional supervision, conduct regulation, functional oversight, transparent (penny-to-penny) monitoring, and continuous supervision—has been fully implemented and is now delivering precise impact.
Looking back over the years, 2020 marked a significant turning point. That year, the "Notice on Standardizing Traceability Management of Internet Insurance Sales Practices" was implemented first, and the "Interim Measures for Supervision and Administration of Internet Insurance Business" were officially released (effective from 2 in 2021). The former focuses on standardizing internet insurance sales practices, while the latter strengthens the principle of licensed operations and information disclosure, reflecting the "institutional supervision" and "behavioral supervision" within the five-in-one regulatory framework.
Notably, the background for issuing the two internet insurance regulatory documents above is closely tied to the frequent industry chaos and persistently high consumer complaints at the time. Public data shows that in 2019, regulators received a total of 1.99 thousand internet insurance consumer complaints, a year-over-year increase of 88.59%, representing 7 times the complaint volume of 2016. Issues such as misleading sales and disguised forced bundling were prominent, significantly undermining consumers' sense of gain.
Subsequently, regulators further refined rules for specific segments of the online insurance market, issuing the "Notice on Further Standardizing Certain Matters Regarding Internet Personal Insurance Business by Insurance Institutions" in 2021 and the "Notice on Strengthening and Improving Regulatory Measures for Internet Property Insurance Business" in 2024. These measures aim to set entry thresholds for personal and property insurers offering online insurance products and to standardize market conduct.
The Notice on Further Standardizing Online Insurance Business issued in 2024 by the Property and Casualty Department of the National Financial Regulatory Administration directly targets the non-compliant promotion and sale of insurance products via internet self-media through "affiliation" arrangements. This reflects a "piercing" regulatory approach, extending oversight from whether individual social media influencers hold licenses to verifying whether those licenses are genuinely affiliated with licensed institutions, whether such institutions exercise substantive control, and whether business operations have been outsourced or subcontracted.
By 2026, "functional regulation" has gradually become a focal point of industry governance. Experts note that functional regulation encompasses all financial functions and innovations within the regulatory framework, adhering to the principle of "same business, same standards." It ensures consistent oversight of similar financial activities across institutions, sectors, and markets, preventing regulatory arbitrage and gaps.
The new regulations on online financial sales issued jointly by eight departments in 2026 year 4 month follow the principle of "similar business, similar regulation" by unifying marketing supervision standards for various financial products such as insurance and deposits, thereby eliminating regulatory arbitrage opportunities.
From this perspective, the "Ten Prohibitions" negative list in the current draft for public consultation represents both a granular implementation of functional regulation and an extension of conduct regulation into execution details such as marketing practices, payment management, product design, and channel management.
From unifying industry-wide standards to precisely addressing systemic issues in niche sectors, it is evident that the ultimate goal of this round of financial product online sales regulation is to return financial marketing to its core principles: licensed operations, information transparency, and prioritizing consumer rights.
