Регулятор опублікував оновлений негативний список особистого страхування, зупинено медичне страхування з низькою захищеністю, а також обіцянки щодо дивідендних страхувань.

21st Century Economic Herald reporter Lin Hanyang

In the deep end where the personal insurance industry is accelerating its transition to high-quality development, the regulatory “red line” on product compliance and risk prevention has tightened again.

A reporter with 21st Century Economic Herald learned from within the industry that the National Financial Regulatory Administration has recently officially issued the 《Personal Insurance Product “Negative List” (2026 Edition)》 (hereinafter referred to as “《Negative List (2026 Edition）》”) to all personal lines insurance companies. Compared with the previously issued 《Personal Insurance Product Negative List (2025)》 (hereinafter referred to as “《Negative List (2025 Edition）》”), which had 103 articles, the 《Negative List (2026 Edition）》 has been slightly expanded to 105 articles.

Data show that in 2025, the insurance industry’s gross written premium for original insurance historically surpassed the 60k yuan mark, reaching 6.12 trillion yuan, an increase of 7.43%. Among this, the gross written premium for original personal insurance was 4.65 trillion yuan, up 9.05%, becoming the core engine of industry growth. Against the backdrop of continued expansion of industry scale, improper practices such as product homogenization, deviation in liability design, and sales misrepresentation still show signs of resurgence. In the view of industry insiders, the issuance of the 《Negative List (2026 Edition）》 indicates that regulators are guiding the industry back to its保障本源 with higher standards and stricter requirements.

New clauses strengthen standardization in the medical and dividend fields

After sorting through the documents, the reporter found that the 《Negative List (2026 Edition）》 continues the previous framework structure, divided into four core sections: product clause wording, product liability design, product premium rate determination and actuarial assumptions, and product submission and management. Compared with the 《Negative List (2025 Edition）》, the 2026 Edition has in multiple places made targeted “patches” and upgraded supervision to a stricter level.

First, in the section “Product Clause Wording,” the 2026 Edition newly adds Article 27, which stipulates: “In medical insurance product clauses, agreements on prescription review are unreasonable; the agreement sets the prescription review party as a third-party service provider rather than an insurance institution; and it does not clearly specify the audit responsibility that the insurance company should assume.”

Industry insiders analyze that as commercial health insurance’s coverage of special drugs and innovative drugs continues to expand, prescription review has become a key link in claim settlement risk control. For some insurers, to shift operational costs, they outsource the entire prescription review authority to a third-party service provider (TPA). Once a claim dispute arises, the insurance company and the TPA often end up passing the blame to each other. This regulatory move clearly requires insurance companies to bear the main responsibility for review, thereby effectively safeguarding consumers’ lawful rights and interests in the process of drug use and claim settlement.

Second, against the backdrop of sustained falling interest rates and lowered predetermined interest rates for traditional insurance, dividend-linked policies have become popular with both insurers and consumers thanks to the model of “guaranteed returns + floating dividends.” In 2025, personal insurance companies generally stepped up efforts in dividend-linked policies, and their business share increased significantly. However, sales misrepresentation problems have also risen as a result.

To prevent future risks of sales misrepresentation, in the third part, “《Negative List (2026 Edition）》,” the 《Negative List (2026 Edition）》 newly adds Article 86 as a red line: “In the policyholder’s explanation of a dividend-type insurance product, the dividend distribution ratio promised in the dividend distribution policy exceeds the level of the dividend distribution ratio shown in the benefit illustration.” This means regulators will never allow insurers to make inflated promises about dividend distribution in the policyholder’s explanation. They require that the written dividend distribution policy must maintain strict actuarial consistency with the actual benefit illustration, curbing illegal marketing from the source.

Actuarial assumptions matched to the new life table

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

For example, in the dimension of “Product Liability Design,” based on the original “《Negative List (2025 Edition）》” provisions—namely “the insurance product’s protective function is weakened; the nursing insurance product only includes nursing liability caused by accidents; and the annuity insurance product has neither protective function nor savings function”—the 《Negative List (2026 Edition）》 greatly expands restrictions on medical insurance, adding “medical insurance that sets an excessively high deductible or an excessively low赔付比例 (payout ratio); and medical allowance products of the fixed benefit type where the insured amount is too low.” This further compresses the space for the “low protection, high cost” distortion in medical insurance.

针对近年来部分公司利用概念替换进行监管套利的乱象，《负面清单（2026版）》防线进一步前移。《负面清单（2025版）》曾明确叫停“年金保险、两全保险比照增额终身寿险的增额形式设计”。

However, as the increased-amount whole-life annuity policy (增额终身寿险) faces strict regulation, some insurers try to “swap in” through the form of nursing insurance. Accordingly, Article (49) of the 《Negative List (2026 Edition）》 newly adds a prohibition: “A nursing insurance with a non-whole-life insurance term that is designed in the form of the increased-amount whole-life annuity.” This blocks the “increased-amount-like” financial-management loophole in nursing insurance.

If product clause wording and liability design are the “front side” of personal insurance products, then premium rate determination and actuarial assumptions are the “inner side” that determines the product’s stable operation. In this core area, the 《Negative List (2026 Edition）》 reflects a major iteration of the industry’s underlying actuarial infrastructure.

The biggest change is reflected in the application rules for the industry experience life table. Article 73 of the 《Negative List (2025 Edition）》 focuses on whether the life table used to evaluate statutory reserve provisions for insurance products is consistent with the requirements in the “Notice of the China Insurance Regulatory Commission on matters related to the use of the 《China Personal Insurance Industry Experience Life Table (2010–2013)》.”

And in the 《Negative List (2026 Edition）》, Article 74 has comprehensively updated this underlying standard, requiring strict alignment with the “Notice of the National Financial Regulatory Administration on matters related to the publication and use of the 《China Personal Insurance Industry Experience Life Table (2025)》.”

The 《China Personal Insurance Industry Experience Life Table (2025)》 (commonly known in the industry as the fourth set of life tables) has been implemented in full starting from January 1, 2026. Compared with the previous version, the new life table reflects that the life expectancy of residents in China has increased by about 10 years, and the child mortality rate has significantly improved.

Against this backdrop, the 2026 negative list further proposes strict requirements: “Do not prudently judge the product’s main liabilities as required and choose the appropriate category of incidence rate table. For the medical expense compensation medical liability included in health insurance, evaluation assumptions related to medical expenses must not fail to consider the medical expense inflation factor as required.”

Industry insiders analyze that as average life expectancy generally increases, retirement-oriented products that cover longevity risk, such as annuity insurance, face greater pressure for long-tail benefit payments; at the same time, long-term medical expense inflation is an indisputable objective fact. Regulators require that the medical expense inflation factor be forcibly considered in actuarial assumptions for health insurance in order to prevent medical insurance products from facing huge payment gaps in the future, and to compel insurers to improve refined pricing and risk management capabilities across different time horizons.

“Report & File, Execute in Line” further deepened

The 《Negative List (2026 Edition）》 further strengthens expense control and channel compliance requirements, further refining the execution of “report & file, execute in line.”

Specifically, the 《Negative List (2025 Edition）》 prohibited “sales channels simultaneously submitting multiple items among ‘personal agency, internet agency, bank postal agency, and brokerage agency,’ which does not meet the related requirements of ‘report & file, execute in line.’” Based on this, the 《Negative List (2026 Edition）》 focuses the applicable subjects more precisely and modifies it to: “For long-term insurance sales channels, submitting multiple items among ‘personal agency, internet agency, bank postal agency, and brokerage agency’ simultaneously, which does not meet the related requirements of ‘report & file, execute in line.’”

So-called “report & file, execute in line” means that insurance companies should strictly implement insurance terms and premium rates that have been filed for record, ensuring that the filed content is completely consistent with actual operating conduct, and eliminating the chaos of “one set in the record, another set in execution.”

“Report & file, execute in line” was first implemented through bank-insurance and bancassurance channels, and then rapidly rolled out to all channels such as personal agents and brokerage agencies. A securities firm research report points out that “report & file, execute in line” is expected to improve the industry expense ratio, reduce overall operating costs, and enhance insurers’ ability to precisely price risks.

Regarding filing materials, the 《Negative List (2026 Edition）》 continues to emphasize the authenticity and consistency of expense assumptions. The behaviors listed as prohibitions include: “If the filing expense assumptions for insurance products are inconsistent with actual expenses; if expense descriptions are unclear and expense level settings are unreasonable; if profit test expenses, sales expenses, and total available expenses are higher than the pricing expenses; and if various expenses lack internal logical consistency,” etc.

(Editor: Qian Xiaorui)

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