China (mainland) — Conduct, Safeguarding & Promotions

Conduct, Safeguarding & Financial Promotions

China's Financial Product Online Marketing Management Rules, jointly issued by the People's Bank of China, the Ministry of Industry and Information Technology, the State Administration for Market Regulation, the National Financial Regulatory Administration, the China Securities Regulatory Commission, the China National Intellectual Property Administration, the Cyberspace Administration of China and the State Administration of Foreign Exchange on 21 April 2026, entered into force on 30 September 2026. The instrument represents a conduct-first intervention into payment-checkout design, with clear supervisory allocation across the issuing regulators under its Article 28: the People's Bank of China covers payment, credit-reporting and credit-rating activity, the National Financial Regulatory Administration covers banking and insurance, the China Securities Regulatory Commission covers securities, funds and futures, and the State Administration of Foreign Exchange covers foreign-exchange activity. This functional allocation was confirmed via a central rule text republished by the Xinjiang Department of Justice, giving it a firmer evidentiary footing than the more granular checkout-UX provisions discussed below.

Reporting on the rule's Article 12 indicates that non-bank payment institutions are barred from including loan and asset-management products among payment-instrument options presented to a user at checkout, and that checkout pages must display payment tools in a zone visually separated from credit and wealth-management products. This obligation applies specifically to non-bank payment institutions rather than banks, reflecting a bank-nonbank distinction that matters materially here: the rule targets the checkout surfaces operated by large non-bank payment ecosystems, where the historical practice of surfacing credit products alongside payment options at the point of transaction has been most prevalent. The Article 12 reporting itself traces to secondary pinpoint coverage rather than an independently cross-checked primary gazette citation, which should temper confidence in the precise wording while the underlying thrust, checkout-level separation of payment from credit/wealth cross-selling, is corroborated by the commencement-date compliance activity described below.

Consistent with the 30 September 2026 commencement date, state media reporting from mid-September 2026 described industry self-inspection and checkout-UX rectification activity underway among major internet payment platforms, language consistent with Alipay- and WeChat Pay-adjacent ecosystems, as they adjusted checkout flows ahead of the rule taking effect. This pattern of pre-commencement rectification is itself evidence that platform operators treated the obligation as substantive and enforceable rather than aspirational.

Outlook

The principal question for the coming period is implementation consistency: whether the Article 12 checkout-separation requirement is applied uniformly across China's major non-bank payment platforms in the months following the 30 September 2026 commencement date, or whether enforcement intensity varies by platform size or product mix. The four-way functional supervisory split under Article 28 gives each regulator a bounded lane but also creates a coordination question for checkout designs that cut across payment, credit and wealth-management products simultaneously, a combination that is common in the integrated super-app checkout experiences operated by China's largest payment platforms.

W1bConduct, Safeguarding & Promotions1 judgmentConfirmedconfirmed 2026-07-04▾#

Conduct, Safeguarding & Financial Promotions

Outlook

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