Practice · Fintech and Digital Assets
Digital Platforms and Financial Market Infrastructure
Financial market infrastructure in China has been governed by unified PBOC and CSRC measures since 1 October 2025. This page explains which systems are covered, what the measures require of domestic and foreign operators, how digital platforms may work with licensed institutions and what the new digital RMB model means.
Key takeaways
- PBOC and CSRC Order [2025] No. 7 took effect on 1 October 2025.
- The measures cover custody, clearing, trading, trade repositories, important payment systems and credit reporting.
- Overseas infrastructure serving mainland participants must meet conditions applied on a reciprocal basis.
- Bank internet loan facilitation rules took effect on 1 October 2025.
- Digital RMB wallet balances at banks have earned interest since 1 January 2026.
Financial market infrastructure in China: what is regulated
Financial market infrastructure in China is now subject to a unified set of rules. The Measures for the Supervision and Administration of Financial Infrastructure, issued jointly by the People's Bank of China (PBOC) and the China Securities Regulatory Commission (CSRC) as Order [2025] No. 7, took effect on 1 October 2025. They cover six types of infrastructure: financial asset registration and custody systems; clearing and settlement systems, including central counterparties; trading facilities; trade repositories; important payment systems; and basic credit reporting systems.
Alongside the infrastructure rules sit the regulations that govern digital platforms when they distribute or facilitate financial products. Together, these two layers determine who may operate the systems through which money and securities move in China, and on what terms technology platforms may connect users to licensed financial institutions.
The distinction matters in practice. An infrastructure operator is itself a regulated, systemically relevant institution, with its own governance, capital and recovery obligations. A digital platform, by contrast, is usually a distribution or technology channel whose regulatory exposure arises through the licensed institutions it works with. Many international businesses touch both layers: an exchange or clearing house that admits mainland members, a custodian that links to mainland depositories, or a technology vendor supplying systems to an operator or to a platform's licensed partners.
The six categories of infrastructure
The table below sets out the six categories with examples of the kinds of systems generally associated with each. Whether a particular system falls within a category, and which regulator leads, should be confirmed for each case.
| Category | Function | Examples of systems of this kind |
|---|---|---|
| Registration and custody | Recording ownership and holding financial assets | Securities and bond central depositories |
| Clearing and settlement | Netting, settling and guaranteeing trades, including central counterparties | Securities and interbank clearing houses |
| Trading facilities | Organised venues for trading securities, futures, bonds and currencies | Stock and futures exchanges; the interbank market trading system |
| Trade repositories | Collecting and storing transaction data for regulators | Derivatives reporting systems |
| Important payment systems | Large-value, retail and cross-border payment processing | Central bank payment systems; the RMB cross-border interbank payment system; clearing for bank cards and online payments |
| Basic credit reporting | Collecting and providing credit information on individuals and businesses | The central bank's credit reference system and licensed personal credit reporting institutions |
Key features of the 2025 measures
| Area | Main requirements reported for the 2025 measures |
|---|---|
| Governance | Clear and transparent governance and accountability arrangements, publicly disclosed |
| Risk management | A risk management committee; management of credit, liquidity and market risk; liquid net assets covering at least six months of operating expenses |
| Technology and data | Disaster recovery; personal information and important data collected in China stored in China; cross-border transfers only in line with national rules |
| Records | Original records and important data kept for at least 20 years unless other laws provide otherwise |
| Reporting | Annual financial reports and prompt reporting of major incidents such as system failures or data leaks |
| Recovery and exit | Recovery plans; regulators may take disposal measures and require exit |
| Systemic importance | Identification criteria based on participants, market share and substitutability; macroprudential oversight by the PBOC |
| Foreign operators | Overseas infrastructure serving mainland participants must meet conditions, including operating experience and reporting, applied on a reciprocal basis |
The measures sit on top of sector laws, including the PBOC Law, the Securities Law and the Futures and Derivatives Law, which took effect on 1 August 2022 and provides the legal basis for central counterparty clearing and close-out netting in derivatives. A summary of the order is available in this report on PBOC and CSRC Order [2025] No. 7.
The thrust of the measures is consistent with the international Principles for Financial Market Infrastructures, which emphasise governance, credit and liquidity risk, operational resilience and recovery. International operators will recognise many of the concepts, but should not assume that compliance with home-country rules automatically satisfies the Chinese requirements, particularly on data localisation, record retention and incident reporting.
Cross-border financial market infrastructure in China and connectivity
For international institutions, the most significant aspect of the measures is the treatment of offshore infrastructure that serves mainland participants. Clearing houses, trading venues, trade repositories and settlement systems located outside China that admit mainland members, or provide services to them, need to assess whether they fall within the cross-border provisions and what reporting and eligibility conditions apply. Reciprocity means that the outcome may depend on how the operator's home regulator treats Chinese infrastructure.
Investment in a mainland infrastructure operator raises separate questions. Shareholders and changes in control are approved by the PBOC or CSRC, and the governance, risk, data and recovery requirements in the 2025 measures should be reflected in due diligence, shareholder agreements and any technology transfer or outsourcing arrangements with a foreign parent.
The measures also matter for mutual market access schemes such as Stock Connect, Bond Connect, Swap Connect and the cross-boundary Wealth Management Connect in the Greater Bay Area, which depend on links between mainland and Hong Kong infrastructure. Changes to eligibility, quotas or settlement arrangements in these schemes are announced jointly by mainland and Hong Kong authorities. See Hong Kong-mainland market connectivity.
The reciprocity point cuts both ways. Mainland operators that want to serve participants in the EU, UK or US must meet those jurisdictions' recognition or exemption regimes for third-country clearing houses and trading venues, and those regimes increasingly look at data access, supervisory cooperation and operational resilience. Cross-border projects therefore often require parallel work in several jurisdictions on the same set of facts.
Decision points for overseas operators and participants
The questions an international business needs to answer depend on its role. The table below is a starting point for scoping work on financial market infrastructure in China; it is not a substitute for a case-by-case review.
| Your position | Key question | Typical first step |
|---|---|---|
| Overseas exchange or clearing house admitting mainland members | Do the cross-border provisions of the 2025 measures apply, and on what reciprocal conditions? | Map mainland members and services; review home-regulator arrangements with the PBOC and CSRC |
| Global custodian or bank using Connect schemes | How do scheme rules and infrastructure rules allocate settlement and data responsibilities? | Review scheme documentation and client agreements |
| Investor in a mainland operator | What approvals and ongoing shareholder obligations apply? | Regulatory due diligence and approval plan |
| Technology or cloud vendor to an operator | What outsourcing, data localisation and audit terms will the operator need to impose? | Review contract templates against the measures |
Data localisation in the 2025 measures interacts with the general data export regime. An offshore infrastructure provider that receives mainland participants' data, or a mainland operator that uses overseas cloud or group systems, should map its data flows against both the infrastructure rules and the cross-border data provisions before changing systems or vendors. See cross-border data transfer.
Digital platforms and financial services
China's large digital platforms remain important channels for payments, lending, wealth management and insurance, but they now operate through licensed subsidiaries and partnerships with licensed institutions. Recent rules continue to tighten those partnerships:
- The NFRA's notice on commercial banks' internet loan facilitation, effective 1 October 2025, requires bank head offices to manage cooperation centrally, apply admission standards and publish lists of partner platforms, control platform and credit enhancement fees, and ensure that platforms do not charge borrowers interest or fees. Banks have since narrowed their partner lists, with some partners limited to running off existing loans.
- Online distribution of funds, insurance and wealth management products must be carried out by, or on behalf of, licensed institutions, with clear disclosure of the product provider.
- Competition law applies to platform conduct in financial services, including self-preferencing and exclusive dealing. See abuse of dominance.
Illustrative example: redesigning a loan facilitation partnership
The following example is hypothetical. A consumer platform has introduced borrowers to several banks for years, receiving a share of interest income and charging borrowers a service fee. Under the 2025 notice, the platform must be on each bank's published partner list, borrowers can no longer be charged by the platform, and the bank must set and control the platform's fees. The parties therefore restructure: the bank pays a service fee for marketing and technology services at a level it has approved, credit decisions and pricing sit with the bank, and the platform's disclosures name the bank as lender.
The restructuring also prompts a data review. Customer information collected by the platform and shared with the bank needs a lawful basis and appropriate consent under the Personal Information Protection Law, and the bank must be able to show that its own risk models, not the platform's, drive credit decisions.
The digital RMB and payment infrastructure
The digital RMB moved to a new model on 1 January 2026 under a PBOC action plan. According to Xinhua's report, digital RMB held in bank wallets is now an account-based liability of the commercial bank, real-name wallet balances earn interest, balances fall within deposit insurance and count towards the reserve requirement base, and non-bank payment institutions must hold 100% digital RMB margin. The plan also provides for an international operations centre in Shanghai and wider use of the multilateral central bank digital currency bridge for cross-border settlement. See payments and bank card clearing.
For merchants, platforms and foreign banks, the practical effect is that digital RMB acceptance and wallet services are increasingly integrated with ordinary bank and payment relationships. Contracts with acquirers and payment institutions should address digital RMB settlement, reconciliation and data handling alongside traditional channels.
Compliance roadmap for financial market infrastructure in China
Operators, foreign infrastructure serving mainland members, and institutions investing in or supplying financial market infrastructure in China can approach the 2025 measures in a structured way.
- Classify. Determine whether the system falls within one of the six categories, or whether the business is a participant, investor or vendor rather than an operator.
- Identify the regulator. Confirm whether the PBOC, the CSRC or both supervise the system, and whether sector rules add separate approvals.
- Gap analysis. Compare governance, risk, liquidity, data, record-keeping and recovery arrangements with the measures.
- Data map. Identify personal information and important data, where they are stored and any cross-border flows, including group and cloud services.
- Contracts. Update membership rules, link-up agreements, outsourcing and technology contracts to reflect reporting, audit and exit requirements.
- Incident and recovery. Test incident reporting lines and recovery plans, and align them with home-country requirements.
- Monitor. Track implementing guidance, systemic importance designations and the progress of the draft Financial Law.
Technology vendors and investors
Vendors are not operators, but the obligations that the 2025 measures place on operators flow down to them through contracts. Operators of financial market infrastructure in China need disaster recovery, incident reporting, record retention and data localisation that their suppliers can support. Vendors should therefore expect detailed security, audit, business continuity and exit provisions, and may need to show that systems serving a mainland operator keep relevant data within China. Foreign vendors supplying core systems also need to consider export control rules in their home jurisdictions and Chinese rules on network product security.
Investors face a different set of issues. A stake in an operator brings shareholder qualification reviews, limits on influence over operational decisions, and continuing obligations to support recovery plans. Transaction documents should allocate the time and risk of regulatory approval, address what happens if approval is refused or conditioned, and preserve the operator's independence in the way regulators expect. See securities and futures firms for related licensing questions.
Common mistakes include treating the measures as relevant only to domestic operators, underestimating the 20-year record retention requirement when choosing systems, and leaving data localisation until after a vendor has been selected.
What to watch
A draft Financial Law received its first reading in June 2026 and is expected to strengthen central oversight of financial activity, including infrastructure. Further implementing guidance on the 2025 measures, the identification of systemically important infrastructure and the treatment of overseas operators is likely. Developments in tokenised settlement, including the requirement in the February 2026 virtual currency notice that any approved onshore RWA business be conducted on specified financial infrastructure, may also shape the role of infrastructure operators. See RWA tokenisation and our overview of fintech and digital assets.
Three further themes are worth monitoring. First, the treatment of cross-border operators may be shaped by bilateral supervisory arrangements, so developments in mainland cooperation with Hong Kong, Singapore, the EU and the UK can change the practical position for foreign financial market infrastructure in China. Second, further opening of Connect schemes, including product and participant eligibility, tends to arrive through joint announcements rather than new legislation. Third, operational resilience and cyber incident reporting expectations are rising globally, and groups running financial market infrastructure in China alongside operations elsewhere will want a single incident framework that meets the strictest applicable timelines.
How TRW & Co helps
We work with international exchanges, clearing houses, custodians, banks, platforms and technology providers on the cross-border dimension of China's financial infrastructure and platform rules. We help clients understand how the Chinese regulatory environment applies to their services, design access and partnership models, negotiate membership, link-up, outsourcing and cooperation agreements, and advise on the laws of the jurisdictions in which our lawyers are qualified. Where PRC legal advice or engagement with the PBOC, CSRC or NFRA is required, we coordinate licensed PRC law firms within a single project plan. To discuss your project, please contact us.
Frequently asked questions
Does an overseas clearing house need approval to serve Chinese members?
Overseas infrastructure that provides services to mainland participants should assess whether it falls within the cross-border provisions of the 2025 measures. Reported conditions include operating experience and reporting obligations, applied on the basis of reciprocity. Separate approvals may also be needed under the Futures and Derivatives Law or for specific connectivity schemes, so each service should be reviewed individually.
Can a platform earn a share of loan interest from a partner bank?
The 2025 NFRA notice requires banks to set and control fee standards for platform services and credit enhancement, and prohibits platforms from charging borrowers. Fees linked directly to interest margins can raise questions about whether the platform is in substance lending or pricing credit. Fee arrangements should reflect services actually provided and be reviewed against the notice.
Is the digital RMB a central bank liability or a bank deposit?
Under the model in effect since 1 January 2026, digital RMB held in commercial bank wallets is treated as an account-based liability of the bank, with interest on real-name wallet balances and deposit insurance coverage. The central bank continues to set rules and operate core infrastructure, while banks operate wallets and carry anti-money laundering responsibilities.
Are credit reporting systems treated as financial infrastructure?
Yes. The 2025 measures list basic credit reporting systems among the six categories of financial infrastructure, alongside custody, clearing, trading, trade repositories and important payment systems. Credit reporting businesses also remain subject to the PBOC's licensing and conduct rules for the credit reporting industry, so operators and their technology partners need to consider both layers of regulation.
Sources
- Report on PBOC and CSRC Order [2025] No. 7: Measures for the Supervision and Administration of Financial Infrastructure
- Xinhua: New digital RMB framework takes effect (January 2026)
- Yicai: NFRA notice on commercial bank internet loan facilitation (effective 1 October 2025)
- Xinhua: Draft Financial Law submitted to the NPC Standing Committee for first reading (June 2026)
- PBOC and seven other departments: Notice on Further Preventing and Disposing of Risks Relating to Virtual Currencies (Yin Fa [2026] No. 42)
General information only, not legal advice. TRW & Co’s Shenzhen representative office does not provide PRC legal services; where a PRC legal opinion is required we work with licensed PRC law firms.