After an eight-month transition window, the Measures for the Administration of Information Disclosure of Asset Management Products of Banking and Insurance Institutions will officially take effect on September 1, 2026, replacing a patchwork of inconsistent rules with a single, binding standard for how China’s banks, trust companies and insurance asset managers communicate with investors.

Issued by the National Financial Regulatory Administration (NFRA) as Order No. 10 of 2025 on December 22, 2025, the Measures comprise six chapters and 35 articles and apply to all asset-management trust products, wealth-management products and insurance asset-management products issued and managed by banking and insurance institutions within mainland China. From September 1, any prior regulatory provisions that conflict with the new Measures will be superseded automatically.

The rules embody the regulator’s “same business, same standard” philosophy, unifying disclosure obligations across three product categories that were previously governed by separate — and often divergent — norms. At the same time, the framework distinguishes between public (publicly offered) and private placements, and leaves room for product-specific self-regulatory specifications to be drafted by industry associations.

A Full-Lifecycle “Three-Clarity” Framework

The Measures organise disclosure duties along the entire product life cycle, pursuing what NFRA officials describe as the “three clarities”:

• “See clearly” at the offering stage — Product prospectuses and contracts must clearly present the performance comparison benchmark, including the rationale for its selection, its calculation methodology, and its relationship to the product’s strategy and underlying assets. A prominent reminder that “the benchmark is not an expected return” is mandatory.
• “Understand clearly” during operation — Periodic reports must truthfully and accurately disclose net asset values, return performance and the composition of invested assets. The Measures strengthen the timely disclosure of material events that could affect investors.
• “Calculate clearly” at termination — Maturity announcements or liquidation reports must lay out fees charged, income distributions and the allocation of any residual assets.

For non-cash-management products, period-end disclosures must include share net value, cumulative net value, total net assets, period return and income distribution. Cash-management products must separately disclose period-end total net assets and period annualised returns — a requirement newly added in the final text.

What Changed from the Draft

Comparing the final Measures with the exposure draft released in May 2025 reveals several targeted refinements. Professional institutions issuing audit opinions, legal opinions or similar documents for disclosure purposes must now exercise due diligence, and their output may not contain false records, misleading statements or material omissions. Where a product provides for investor meetings or beneficiary assemblies, the prospectus or contract must now disclose the procedures and rules for convening, deliberating and voting. The provisions on performance comparison benchmarks were also adjusted: except under specific circumstances, products may choose not to disclose a benchmark; but publicly offered products showing past performance must also disclose the product’s establishment date, and those established less than one month must show the benchmark alongside past performance.

Public vs. Private, and the “1+3” Rule System

Reflecting the different risk profiles of investor bases, the Measures impose stricter obligations on publicly offered products. Public-product information must be disclosed at minimum through the industry’s unified channel — China Wealth Management Website (中国理财网) — and may additionally be published through nationwide financial mainstream media or other channels agreed with investors. Private products may be disclosed through channels agreed with investors, subject to regulatory requirements. Information disclosed across different channels must be consistent.

The Measures form the “1” of a “1+3” architecture. The China Trust Association and the China Banking & Insurance Asset Management Association, together with the relevant product registration entities, will develop three self-regulatory specifications tailored to trust, banking and insurance asset-management products respectively.

Penetration disclosure receives explicit statutory backing: where a product invests in another product subject to the Guiding Opinions on Regulating Asset-Management Business of Financial Institutions, the underlying product’s manager (except for publicly offered securities investment funds) must promptly assist in providing truthful, accurate and complete information for look-through reporting. Publicly offered products’ periodic reports must separately list the top ten assets both before and after penetration, by name, size and proportion.

Industry Races to Meet the Deadline

With the effective date days away, institutions are in the final sprint of compliance work. According to data compiled by financial information providers, since August alone, more than 20 wealth-management subsidiaries have issued nearly 3,000 announcements adjusting performance comparison benchmarks; on August 20, China Everbright Wealth Management released over 800 sales-document revision notices in a single day, and ICBC Wealth Management followed on August 24 with revisions covering more than 600 products. Combined sales-file adjustment notices across the industry have totalled nearly 1,000 in August.

The surge reflects both a mechanical update of product documents and a substantive “re-anchoring” of performance benchmarks. Facing a declining interest-rate environment and the regulator’s restrictions on arbitrary benchmark adjustments, many managers are shifting from fixed-number or range-based benchmarks to formula-based, index-linked benchmarks that track market rates. The transition, however, presents a comprehension challenge: even industry practitioners acknowledge that formula-driven benchmarks — which may combine deposit rates, bond indices and equity indices with varying weights — can be opaque to ordinary investors accustomed to reading a single number.

On the infrastructure side, the Banking Wealth-Management Registration & Custody Center had required all wealth-management managers to submit platform-access acceptance applications by July 10, with full acceptance targeted by August 10 ahead of the September 1 go-live. As of early July, 15 managers — including three wealth-management subsidiaries and 12 commercial banks — had passed acceptance. An industry scan of 32 wealth-management companies’ disclosures on China Wealth Management Website showed an average disclosure rate of only 44%, underscoring the gap that must close before the rules bite.

Enforcement and Penalties

NFRA and its local offices will conduct ongoing supervision of disclosure practices, factoring them into non-onsite regulation, onsite inspections, and the regulatory ratings of trust companies, wealth-management subsidiaries and insurance asset-management firms. Violations — including false or misleading disclosures, unauthorised promises of returns, performance predictions, or the public disclosure of private-product information — may trigger regulatory measures, administrative penalties, or adverse-conduct records reported to the offender’s governing department. Documents and working papers related to disclosure must be retained for at least 15 years beyond a product’s contractual termination.

The Measures mark the most significant overhaul of investor-disclosure obligations in China’s banking and insurance asset-management sector in recent years. For an industry that has long grappled with inconsistent standards across product types, benchmark opacity and limited look-through visibility, September 1 represents not merely a compliance deadline but the start of a new competitive paradigm — one in which transparency and genuine investment-management capability, rather than benchmark marketing, become the primary differentiators.