China’s National Financial Regulatory Administration (NFRA) on 9 October published revised rules on how property and casualty insurers develop their products. The Provisions on the Management of Insurance Product Development by Property Insurance Companies, signed on 30 September, take effect on 1 November 2026 and replace a 2016 guideline from the former China Insurance Regulatory Commission. The text is aimed at the products that have caused the most trouble in non-motor lines: add-on riders used to rewrite main policies, policies with no real cover sold on price, and rate filings that ignore industry benchmarks. RegMemo’s summary below is based on our own translation of the Chinese-language documents.
Eight types of product are banned outright
The provisions run to eight chapters and 41 articles. Article 7 lists eight kinds of product that P&C insurers may not develop. They include property cover where the insured has no legally recognised interest in the subject matter, cover for events that cause no actual loss, and cover for events that are certain to happen or certain not to happen. Also banned are products that insure speculative risks with a chance of gain, products with no real protection designed only to cut or raise premiums or for “malicious hype”, products that promise to return premiums if no claim is made, and products that carry risk without charging a premium unless NFRA rules allow it.
The premium-refund ban rules out policies that pay money back when no claim is made, which blur insurance with a rebate scheme. The no-premium ban rules out cover handed out as a giveaway alongside another product. Both practices make it hard for a buyer to see what the protection itself costs, which is the consumer harm NFRA’s Q&A says the rules are meant to address.
Riders must stay riders
Chapter 4 is new and deals with add-on cover (附加险). A rider must extend, restrict or adjust the main policy’s policyholder, insured, subject matter, cover, exclusions, period or claims handling. Insurers must assess whether a rider is necessary, and explanatory wording that changes none of those elements should not be developed as a rider.
Article 16 says insurers should not, in principle, develop riders whose policyholder or insured differs from the main policy’s, riders that correct errors in the main policy, riders complete and independent enough to be main policies, or riders with weak links to the main policy. In a question-and-answer companion document, an NFRA official said some companies had designed fairly independent cover as riders and had even used riders to fix mistakes in main policies. The rules also set naming formats for main policies and riders so that the name states the main cover.
Industry model clauses become the default
Article 30 says that where the Insurance Association of China has issued model clauses, or the Actuarial Association of China has issued benchmark pure loss rates, insurers should in principle use them. An insurer that does not must explain the difference and its reasons in its feasibility or actuarial report. That creates a comply-or-explain regime for pricing in the main non-motor lines, and gives supervisors a written record to challenge when a company’s rates diverge from the benchmark.
Named executives carry the liability
The rules require each insurer to set up a product management committee led by its principal executive, and to submit certain filings to that committee, including all products needing approval, financing credit and guarantee insurance, and products that are highly novel, have unusual business models or carry high underwriting risk. Article 37 allocates responsibility by name: the principal executive carries leadership responsibility, the chief compliance officer direct responsibility for policy wording review, and the chief actuary direct responsibility for rate review.
Article 32 adds a review cycle for big sellers. Products making up 5% or more of current written premium must be assessed regularly on sales, cash flow, capital use and profit, every six months for products on the market for under two years and annually after that, with an annual premium adequacy check. Insurers must clean up their product lists every year and deregister non-model clauses unused for three consecutive years, updating the industry platform within 10 days.
Non-motor lines are the target
NFRA describes the provisions as an important measure in P&C supervision and in its “overall governance of non-motor insurance” (非车险综合治理). Motor, agricultural, marine, policy-based credit, short-term health and accident insurance follow their own rules where those exist. For insurers whose books are weighted toward commercial non-motor lines, the rider and benchmark rules are the provisions most likely to force product changes before 1 November, with three weeks between publication and the effective date.
What to watch
- 1 November 2026: the provisions take effect and the 2016 guideline (保监发〔2016〕115号) and a 2014 urgent notice are repealed.
- Insurers’ first annual product reports under Article 34.
- NFRA enforcement against riders that duplicate or correct main policies.
Primary sources
- NFRA, Notice on issuing the Provisions on the Management of Insurance Product Development by Property Insurance Companies (in Chinese), dated 30 September 2026, published 9 October 2026
- NFRA, NFRA issues the Provisions (press release, in Chinese), 9 October 2026
- NFRA, Official answers to reporters’ questions on the Provisions (in Chinese), 9 October 2026
Photo (cropped): N509FZ, CC BY-SA 4.0 via Wikimedia Commons
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