Regulator merilis daftar negatif baru untuk asuransi jiwa, asuransi kesehatan dengan perlindungan rendah dan asuransi dividen yang hanya janji-janji dihentikan

Lin Hanyang, Reporter for 21st Century Business Herald

In the deep waters where the life insurance industry is accelerating its transition toward high-quality development, regulatory red lines for product compliance and risk prevention have once again been tightened.

A reporter from 21st Century Business Herald learned from industry insiders that, the National Financial Regulatory Administration has recently officially issued the “Life Insurance Product ‘Negative List’ (2026 Edition)” to all life insurance companies (hereinafter referred to as “Negative List (2026 Edition)”). Compared with the previously issued “Life Insurance Product Negative List (2025)” (hereinafter referred to as “Negative List (2025 Edition)”) with 103 items, the “Negative List (2026 Edition)” has been marginally expanded to 105 items.

Data show that in 2025, the premium income from original insurance in the insurance industry historically surpassed the 60 trillion yuan threshold, reaching 6.12 trillion yuan, up 7.43% year-on-year; of this, premium income from original insurance for life insurance reached 4.65 trillion yuan, up 9.05% year-on-year, becoming the core engine for industry growth. Against the backdrop of continued expansion in industry scale, irregular practices such as product homogenization, deviation in responsibility design, and sales misguidance still show signs of resurfacing. In the view of industry practitioners, the introduction of the “Negative List (2026 Edition)” indicates that regulatory authorities are guiding the industry to return to the essence of providing protection with higher standards and stricter requirements.

New provisions strengthen standardization in the medical and dividend fields

The reporter’s review found that the “Negative List (2026 Edition)” continues the previous framework structure, consisting of four core sections: product clause wording, product responsibility design, product premium rate determination and actuarial assumptions, and product submission management. Compared with the “Negative List (2025 Edition)”, the 2026 edition has made targeted “patches” and an upgrade in strict supervision in multiple details.

First, in the “product clause wording” section, the 2026 edition newly adds Article 27, which stipulates: “Where it is agreed that the review of prescription for medical insurance policy terms is unreasonable, and the agreement specifies that the prescription review subject is a third-party service provider rather than an insurance institution, and the insurance company’s review responsibilities are not clearly stated.”

Industry insiders analyzed that, as commercial health insurance continues to expand coverage of special drugs and innovative drugs, prescription review has become a key link in claim risk control. Some insurers outsource the entire prescription review right to third-party service providers (TPA) in order to shift operating costs. Once a claim dispute arises, the insurance company and TPA often blame each other. This regulatory measure clearly requires that insurance companies must assume responsibility as the subject of review, and effectively safeguard consumers’ lawful rights and interests in the process of using medication for claims.

Second, against the backdrop of interest rates continuing to decline and the preset interest rates of traditional insurance being lowered, dividend-type insurance, with its model of “guaranteed returns + floating dividends,” has been favored by both insurance companies and consumers. In 2025, life insurance companies generally focused on dividend-type insurance, and its share of business increased significantly. However, problems of sales misguidance have also risen accordingly.

To prevent future risks of sales misguidance, the “Negative List (2026 Edition)” adds in the third section “Negative List (2026 Edition)” a new Article 86 red line: “For the dividend distribution proportion promised in the dividend allocation policy in the product prospectus of dividend-type insurance, where the proportion exceeds the distribution proportion level presented in the interest demonstration.” This means regulators will never allow insurers to make exaggerated promises about dividend allocation in the product prospectus, and requires that the written dividend allocation policy must remain strictly consistent with the actuarial consistency of the actual interest demonstration, in order to curb violations from the source and stop improper marketing.

Actuarial assumptions matched to the new life table

In addition to the two newly added items, the granularity of the “Negative List (2026 Edition)” has been further refined.

For example, in the dimension of “product responsibility design,” the “Negative List (2026 Edition)” builds on the “Negative List (2025 Edition)” by expanding restrictions on medical insurance. It adds: “medical insurance that sets excessively high deductibles or excessively low claim ratios; and insurance amounts that are too low for fixed-benefit medical allowance products,” thereby further compressing the room for the “low protection, high cost” distortion in medical insurance.

In response to the irregular practices in recent years where some companies exploit regulatory arbitrage by substituting concepts, the “Negative List (2026 Edition)” moves the barrier forward further. The “Negative List (2025 Edition)” previously clearly halted the “incremental form design” for annuity insurance and endowment insurance that is made to be similar to the incremental paid-up whole life insurance design.

However, as incremental paid-up whole life insurance is tightly regulated, some insurers have tried to “change lanes quietly” by taking the form of nursing insurance. In response, Article (Forty-Nine) of the “Negative List (2026 Edition)” newly adds a prohibition: “The incremental form design of nursing insurance with a non-life term being made to be similar to the incremental form design of incremental paid-up whole life insurance,” closing the “incremental-like” wealth management loophole of nursing insurance.

If product clause wording and responsibility design are the “appearance” of life insurance products, then premium rate determination and actuarial assumptions are the “inner layer” that determines a product’s稳健 operation. In this core area, the “Negative List (2026 Edition)” reflects a major iteration of the industry’s actuarial underlying infrastructure.

The biggest change is reflected in the application standards for the industry experience life table. Article 73 of the “Negative List (2025 Edition)” focused on whether the life tables used for evaluating the statutory reserve for insurer obligations under insurance products are consistent with the requirements of the “Notice of the China Insurance Regulatory Commission on Matters Concerning the Use of the ‘China Life Insurance Industry Experience Life Table (2010-2013)’”.

Whereas in the “Negative List (2026 Edition),” Article 74 has fully updated this underlying standard, requiring strict alignment with the “Notice of the National Financial Regulatory Administration on Doing Related Matters Regarding the Release and Implementation of the ‘China Life Insurance Industry Experience Life Table (2025)’.”

The “China Life Insurance Industry Experience Life Table (2025)” (i.e., what industry insiders commonly call the fourth set of life tables) has been fully implemented since January 1, 2026. Compared with the previous version, the new life table reflects that the expected life expectancy of our residents has increased by about 10 years, and the child mortality rate has improved significantly.

Against this backdrop, the 2026 edition negative list further proposes strict requirements: “Failing to prudently determine the main responsibilities of the product as required and select the applicable category of incidence rate tables. For medical expense compensation medical responsibilities included in health insurance, the evaluation assumptions related to medical expenses are not considered as required the factor of medical expense inflation.”

Industry insiders analyzed that, with the general extension of average life expectancy, retirement products covering longevity risk such as annuity insurance face greater long-tail payout pressure; at the same time, long-term medical expense inflation is an undisputed objective fact. By requiring regulators to force the inclusion of medical expense inflation factors in actuarial assumptions for health insurance, the aim is to prevent future huge claim shortfalls for medical insurance products and to compel insurers to enhance cross-cycle refined pricing and risk management capabilities.

“Filing for reporting and execution with filing” further deepened

The “Negative List (2026 Edition)” further strengthens cost control and channel compliance requirements, and further details the execution of “filing for reporting and execution with filing.”

Specifically, the “Negative List (2025 Edition)” prohibits sales channels from simultaneously submitting multiple items among “individual agency, internet agency, bank-post office agency, and brokerage agency,” which does not comply with related requirements of “filing for reporting and execution with filing.” Based on this, the “Negative List (2026 Edition)” more precisely focuses the applicable entities, and modifies it to: “For long-term insurance sales channels, submitting multiple items among ‘individual agency, internet agency, bank-post office agency, and brokerage agency’ at the same time does not comply with related requirements of ‘filing for reporting and execution with filing.’”

The so-called “filing for reporting and execution with filing” means that insurance companies should strictly implement insurance clauses and premium rates that have been filed for record, ensuring that the contents filed are completely consistent with actual business conduct, and preventing the chaotic practice of “filing one set and executing another set.”

“Filing for reporting and execution with filing” was first implemented in the bank-insurance channels, and then quickly expanded across all channels such as individual agencies and brokerage agencies. Brokerage research points out that “filing for reporting and execution with filing” is expected to improve the industry expense ratio, reduce overall operating costs, and enhance insurers’ ability to precisely price risk.

In terms of filing materials, the “Negative List (2026 Edition)” continues to emphasize the authenticity and consistency of expense assumptions. Behaviors such as “insurance product filing expense assumptions inconsistent with actual expenses; unclear expense descriptions and unreasonable setting of expense levels; profit testing expenses, sales expenses, and total available expenses higher than pricing expenses; various expenses lacking internal logical consistency,” are all included in the prohibitions.