Regulatory authorities release a new version of the negative list for personal insurance, stopping the approval of low-coverage medical insurance, dividend insurance with empty promises, and other practices.

Reporter Lin Hanya, 21st Century Business Herald

In the deep water where the life insurance industry is accelerating its transition to high-quality development, regulatory red lines on product compliance and risk prevention are tightening again.

A reporter learned from industry sources that the National Financial Regulatory Administration has recently formally issued the 《Negative List for Life Insurance Products (“Negative List” (2026 edition))》（hereinafter referred to as the “《Negative List (2026 edition)》”）to all life insurance companies. Compared with the earlier 《Negative List for Life Insurance Products (2025)》（hereinafter referred to as the “《Negative List (2025 edition)》”）, which had 103 clauses, the 《Negative List (2026 edition)》 has been expanded slightly to 105 clauses.

Data show that in 2025, the insurance industry’s gross premium income for original insurance crossed the 6 trillion yuan mark for the first time in history, reaching 6.12 trillion yuan, up 7.43% year over year. Of this, the gross premium income for original life insurance was 4.65 trillion yuan, up 9.05% year over year, becoming the core growth engine for the industry. Against the backdrop of continued expansion in industry scale, various issues such as product homogenization, deviation in liability design, and sales misguidance are still on the rise. In the view of industry insiders, the introduction of the 《Negative List (2026 edition)》 signifies that regulators are guiding the industry back to its original purpose of providing protection with higher standards and stricter requirements.

New clauses strengthen regulation in the medical and profit-sharing fields

After reviewing the document, the reporter found that the 《Negative List (2026 edition)》 continues the framework structure used previously. It is divided into four core sections: product clause wording, product liability design, product premium rate determination and actuarial assumptions, and product submission and reporting management. Compared with the 《Negative List (2025 edition)》, the 2026 version makes targeted “patches” and upgrades to strict supervision in multiple details.

First, in the section on “product clause wording,” the 2026 version newly adds Clause 27, which stipulates: “If the agreed prescription review arrangements in a medical insurance product’s policy clauses are unreasonable—i.e., the agreement sets the prescription review party as a third-party service provider rather than an insurance institution, and fails to clearly specify the review responsibility that the insurer should assume.”

Industry insiders analyze that, as commercial health insurance continues to expand coverage of specialty drugs and innovative medicines, prescription review has become a key link in claims risk control. Some insurers, to shift operational costs, outsource the entire prescription review authority to third-party service providers (TPA). Once a claims dispute arises, insurers and TPA often push responsibility back and forth. This regulatory move clearly requires insurers to assume the主体 responsibility for review, and to effectively safeguard consumers’ lawful interests in the process of using medicines and filing claims.

Second, against the backdrop of continuously falling interest rates and reductions in the predetermined interest rates for traditional insurance, profit-sharing insurance has gained popularity among both insurers and consumers thanks to its “guaranteed returns + floating profit-sharing” model. In 2025, life insurance companies generally stepped up efforts in profit-sharing products, and their business share increased significantly. However, the issue of sales misguidance also rose along with it.

To prevent future sales-misguidance risks, in the third section “《Negative List (2026 edition)》,” the 《Negative List (2026 edition)》 newly adds Clause 86 as a red line: “For a dividend-type insurance product, the dividend distribution ratio promised in the product prospectus exceeds the distribution ratio level demonstrated by the benefit illustration.” This means regulators will never allow insurers to make inflated promises about dividend distribution in product prospectuses. It also requires that written dividend distribution policies must be actuarially consistent with the actual benefit illustration in a rigorous manner, curbing noncompliant marketing at the source.

Actuarial assumptions matching the new mortality tables

In addition to the two newly added clauses, the granularity of the 《Negative List (2026 edition)》 is further refined.

For example, in the dimension of “product liability design,” on the basis of the existing provisions in the 《Negative List (2025 edition)》—“the weakening of an insurance product’s protection function; and a nursing insurance product only includes nursing liabilities arising from accidental causes; the annuity insurance product has neither a protection function nor a savings function”—the 《Negative List (2026 edition)》 significantly expands restrictions on medical insurance. It newly adds provisions such as “medical insurance with excessively high deductibles or excessively low reimbursement ratios; and medical allowance products of the fixed benefit type with an insurance amount that is too low.” This further compresses the space for medical insurance to morph into a “low protection, high cost” distortion.

Against the backdrop of recent chaos in regulatory arbitrage by using concept substitution, the 《Negative List (2026 edition)》 moves its defenses further forward. The 《Negative List (2025 edition)》 had previously clearly called for stopping the “incremental form designs” of annuity insurance and endowment insurance that imitate the incremental forms of whole life insurance with added amounts.

However, as whole life insurance with added amounts is subject to strict controls, some insurers have attempted to “sneak through” by taking the form of nursing insurance. In response, the 《Negative List (2026 edition)》 adds, in Clause (49) (fourty-nine), a prohibition on “the incremental form design of nursing insurance that is not whole-life in insurance term, when it is structured to match whole-life insurance with added amounts,” closing the “incremental-like” wealth-management loophole in nursing insurance.

If product wording and liability design are the “face” of life insurance products, then premium rate determination and actuarial assumptions are the “substance” that determines stable operation of the products. 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 standards for the industry’s experience mortality tables. Clause 73 of the 《Negative List (2025 edition)》 focuses on whether the mortality tables used to evaluate statutory reserves for insurance product liabilities are consistent with the requirements in the notice from the China Insurance Regulatory Commission regarding the use of the 《China Life Insurance Industry Experience Mortality Table (2010-2013)》 and related matters.

As for the 《Negative List (2026 edition)》, Clause 74 comprehensively updates this underlying standard, requiring strict alignment with the notice from the National Financial Regulatory Administration on “Relevant Matters Regarding the Release and Implementation of the 《China Life Insurance Industry Experience Mortality Table (2025)》.”

The 《China Life Insurance Industry Experience Mortality Table (2025)》 (i.e., the so-called “fourth set” of mortality tables used within the industry) has been fully implemented since January 1, 2026. Compared with the previous version, the new mortality table reflects an increase of about 10 years in the life expectancy of residents in China, and the child mortality rate has improved significantly.

Against this larger background, the 2026-version negative list further proposes strict requirements: “Not prudently judging the category of mortality rate tables applicable to the product’s main liabilities according to the requirements. For the medical expense compensation liabilities included in health insurance, the evaluation assumptions related to medical expenses must consider medical expense inflation factors as required.”

Industry insiders analyze that, as average life expectancy is generally extended, retirement-oriented products that cover longevity risk such as annuity insurance face greater long-tail payment pressure. At the same time, long-term inflation in medical expenses is an objective fact. Regulators require medical expense inflation factors to be forcibly considered in actuarial assumptions for health insurance in order to prevent medical insurance products from facing a massive gap in claims in the future, and to push insurers across planning cycles to enhance their capabilities in refined pricing and risk management.

“Unified reporting of underwriting and premiums” further deepened

The 《Negative List (2026 edition)》 further strengthens expense controls and channel compliance requirements, further refining the execution of “unified reporting of underwriting and premiums.”

Specifically, the 《Negative List (2025 edition)》 prohibited sales channels from simultaneously reporting multiple items among “personal agency, internet agency, bank and postal agency, and brokerage agency,” which does not comply with relevant requirements for “unified reporting of underwriting and premiums.” The 《Negative List (2026 edition)》, building on this, narrows the scope of applicable parties more precisely, modifying it to: “For long-term insurance sales channels, reporting multiple items among ‘personal agency, internet agency, bank and postal agency, and brokerage agency’ at the same time that does not comply with relevant requirements for ‘unified reporting of underwriting and premiums.’”

So-called “unified reporting of underwriting and premiums” means that insurers should strictly execute the insured terms and premium rates that have been filed/recorded, ensuring that the filed content is completely consistent with actual business operations, and eliminating chaotic behavior of “one set for filing, another set for execution.”

“Unified reporting of underwriting and premiums” was first implemented in bancassurance channels, and then quickly expanded across all channels including personal agents and brokerage agents. Securities firm research points out that “unified reporting of underwriting and premiums” is expected to improve industry expense ratios, lower overall operating costs, and enhance insurers’ ability to precisely price risk.

With respect to filing materials, the 《Negative List (2026 edition)》 continues to emphasize the authenticity and consistency of expense assumptions. Prohibited behaviors include: “inconsistency between expense assumptions for insurance product filings and actual expenses; unclear expense descriptions and unreasonable setting of expense levels; profit testing expenses, sales expenses, and total available expenses higher than pricing expenses; and a lack of internal logical consistency among various expenses,” among others.

(Editor: Qian Xiaorui)

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