Country _ Name
China
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Financial advisory and broking services including robo advisory and auto-trading
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FinTechs belonging to this category offer advisory and broking services for investments usually via an internet platform.

Robo advisory services usually offer an investment proposition following a series of questions concerning the personal financial background and the risk-bearing capacity of the user. Sometimes the respective platform also enables the user to directly execute the proposed investment. 

Auto-trading concerns all services which automatically trade on behalf of the customer according to his or her specifications.

Apart from that some FinTechs collect and offer merely or as an ancillary service market information or operate comparison portals to increase the transparency of the capital markets and to help the investor with his decision-making.

There are also FinTech-advertising-services which advertise various financial services or products.

Introduction

Attitude of the country towards modern financial advisory and broking services

As AI time is approaching, there is a potentially huge market for intelligent asset management, which also presents opportunities for the development of modern financial advisory services. However, given the strong regulation over the fund investment advisory business, these institutions have adopted a prudent attitude accordingly.


Legal affairs

Obligations and requirements to provide financial advisory and broking services, or ancillary services described above

To engage in securities and futures investment advisory business, the entity shall obtain an investment consulting services license issued by the CSRC. The applicants shall satisfy relevant qualification requirements, such as the registered capital (more than RMB1 million (equivalent to approximately USD 140 thousand or EUR119 thousand)), proper premise, professional, internal control mechanism. In practice, due to the policy control, it is very difficult to obtain such license issued by CSRC for now. Further, the personnel engaging in securities and futures investment advisory business shall join a licensed investment advisory institution and obtain the securities and futures investment advisory qualification.

The FinTechs in this area should be careful not to make the investment on behalf of customers, rather than providing advice, unless they further obtain the license of a security broker. CSRC continues paying close attention on online investment consulting services. In practice, several FinTechs were imposed with the administrative penalties due to being involved in security trading without the license of a security broker.

Auto trading and broking services are deemed as operating in the security brokerage business, which shall be subject to the license for security business issued by CSRC. The entity holding the security business license issued by CSRC is the security company. The registered capital of the security company shall be no less than RMB50 million (equivalent to approximately USD6.98 million or EUR5.97 million). The net assets of the major shareholders of the security company shall not be less than RMB50 million (equivalent to approximately USD6.98 million or EUR5.97 million); the first major shareholder or/and the controlling shareholder of the security company engaged in business with significant leverage shall have total assets of not less than RMB 50 billion (equivalent to approximately USD6.98 billion or EUR5.97 billion) and net assets of not less than RMB20 billion (equivalent to approximately USD 2.79 billion or EUR2.39 billion).

Additional comments regarding the legal situation for financial advisory and broking services, or adjacent services or what FinTech’s must be aware of in this business area

CSRC issued the Securities Fund Investment Advisory Business Management Measures (Draft for Comments) in 2020, requiring that the net worth of the applicant shall not be less than RMB100 million (equivalent to approximately USD13.96 million or EUR11.94 million). This means that the threshold for engaging in financial advisory services might be further increased in the future. In addition, CSRC issued the Administrative Regulations on Programmed Trading in Securities Market (Trial) in 2024, specifying that the relevant parties (mainly securities companies) which are engaged in securities trading in Security Exchange by issuing the specific orders generated via computer program, shall perform the various obligations, such as reporting, risk management, and IT systems etc. to maintain the operation of such system in compliance. Such new regulation is focusing on securities companied utilizing the computer program to general the trading orders, rather than securities trading based on customer preferences or specifications.  


The current trend is still to tighten the regulation of intelligent investment advisory services, but it is still unknown whether the restrictions will be relaxed in the future to stimulate market dynamics. Considering AI is developing rapidly, it is notice that the top-level design of legislation has shown a clear focus on AI. AI has been included in the annual legislative work plan in the past several years. It is believed that the Chinese authorities may issue new regulations regarding intelligent investment advisory in the near future.


Economic conditions

Market size for financial advisory and broking services as well as adjacent services and biggest companies in this business area

According to Statista Data, the assets under robo-advisors management in China are projected to reach USD3.14 billion in 2025. (Source: Statista, https://www.statista.com/outlook/dmo/fintech/digital-investment/robo-advisors/china, June 2025). There is no official statistical data from China for assets under intelligent management.

According to the China Intelligent Investment Advisory System Study (Q4 2021) report, the top 10 overall ranked smart investment advisory platforms consist of the early established independent third-party institutions, large banks, fund companies, and institutions that rank highly in fund sales, including the Help You Vote of the Group Co., Ltd., Capricorn Wise Investment of China Merchants Bank, Sinan Wise Investment of China Southern Asset Management Co., Ltd. etc. (Source: Tsinghua PBCSF, https://fintechlab.pbcsf.tsinghua.edu.cn/info/1018/1464.htm, February 22, 2022). This report has not been updated beyond 2021, which may be attributed to the Chinese authorities' cautious approach to intelligent investment advisory and the China's slowing economic growth.

Additional comments regarding the economic situation for financial advisory and broking services as well as adjacent services or what FinTech’s must be aware of in this business area

In a comprehensive manner, the development of financial advisory and broking services relying on technologies is still at a relatively early stage, while it is foreseeable that the platforms with the first-mover position will have the market advantage for a long time.



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