Global FinTech Guide
Country Name
Asset and portfolio management
FinTechs belonging to this category offer asset and portfolio management services via an internet platform or software programs and usually manage and dispose of the assets of their customers long or short term according to their specifications without actually holding the property or the possession of those assets. FinTechs, which provide information about and access to overnight or time deposit accounts at national and foreign banks and which execute the transactions to these accounts, also belong to this category. Some FinTechs however only act on request of the customer.

Aside from that some FinTechs offer software or internet solutions enabling users to manage and plan their personal finances on their own by providing graphics, overviews and compilations of their financial data and sometimes indicating financial risks or opportunities, but without actually managing the assets.


Attitude of the country towards modern asset and portfolio management services

With the rapid development of FinTech, business of asset and portfolio management is in the process of remodelling. In China, the financial institutions engaging asset management business keep increasing their investment in FinTech in order to have an advantage in data collection and collation, risk control and personalisation; the regulatory authorities have also imposed more detailed regulatory requirements on the asset and portfolio management services.

Legal affairs

Obligations and requirements to provide asset and portfolio management, or ancillary services described above

Entities engaged in asset management shall be divided into two (2) categories in terms of regulation. The first category is financial institutions regulated by the Chinese Banking and Insurance Regulatory Commission (CBIRC), including but not limited to, banks, trust companies and insurance companies. The second category is financial institutions regulated by the Chinese Securities Regulatory Commission (CSRC), including but not limited to, fund management companies, securities companies, and private equity institutions. There is no unified license/supervision on the general asset and portfolio management services, but the entities engaging in asset management services shall be the said financial institutions and hold relevant licenses. With respect to the operation of online asset management business, the authorities have also issued a series of regulations to impose strict requirements in the aspect of the protection of personal information, platform anti-monopoly, webcast marketing etc.

For unlicensed institutions, CBIRC and CSRC have strictly restricted them from engaging in providing asset and portfolio management services and have particularly strengthened the supervision of online asset and portfolio management business. For example, the latest Monetary Policy Implementation report released by the PBOC points out the necessity of clearing out unlicensed online asset management institutions.

Additional comments regarding the legal situation for asset and portfolio management services or what FinTech’s must be aware of in this business area

It is worth noting that the Chinese authorities have started to clean up the asset management products designed as the “rigid payment” (i.e. the financial institutions guarantee principal and income for the products) since 2018 through the Guiding Opinions on Regulating the Asset Management Business of Financial Institutions (the Opinions). With the four-year rectification period for all the financial institutions, no “rigid payment” asset management product is allowed to be existing by today. Upon the issuance of the Opinions, all market players have made the material internal adjustment with respect to the products and operation rules to satisfy the requirements of the Opinion, which have deeply changed the market circumstance and regulatory system of the asset management business. 

Further, the Chinese authorities have launched the “Cross-Boundary Wealth Management” pilot project in the Greater Bay Area of Mainland China (GBA), Hong Kong and Macao, allowing investors in GBA to purchase the products sold in Hong Kong and Macao, and vice versa. It is an important breakthrough in the development of cross-border asset management business.

Economic conditions

Market size for asset and portfolio management services and biggest companies in this business area

According to the data published by China Trustee Association, China Wealth, Asset Management Association of China, Insurance Asset Management Association of China, the status of each asset management sub-sector is as follows: (i) at the end of the third quarter of 2021, the balance of the assets managed by the trust companies is RMB20.44 trillion (equivalent to approximately USD3.2 trillion or EUR2.9 trillion);  (ii) at the end of 2021, the balance of the assets managed by banks is RMB29 trillion (equivalent to approximately USD4.57 trillion or EUR4.12 trillion);  (iii) at the end of the third quarter of 2021, the scale of asset management business of the public fund management, securities and futures management, private equity fund management is about RMB65.87 trillion (equivalent to approximately USD10.37 trillion or EUR9.36 trillion),  and (iv) at the end of 2020, the cumulative registered scale of asset management business for insurance fund management is RMB21.38 trillion (equivalent to approximately USD3.37 trillion or EUR3.04 trillion).

According to the Top 500 Asset Managers 2021 published by Investment & Pensions Europe (IPE), China Life Asset Management Company Limited ranks first in China and 38th worldwide with total assets of about RMB4.1 trillion (equivalent to approximately USD646 billion or EUR582 billion).

Additional comments regarding the economic situation for asset and portfolio management services or what FinTech’s must be aware of in this business area

The Opinions and other detailed rules have imposed the same requirements on the different types of financial institutions engaging the asset management business. It is conducive to the healthy development of the entire asset management industry, but it also brings more competition to the business.




© 2022, JunHe LLP. All rights reserved by JunHe LLP as author and the owner of the copyright in this chapter. JunHe LLP has granted to Multilaw non-exclusive worldwide license to use and include this chapter in this guide and to sublicense Lexis Nexis, a division of RELX Inc. and its affiliates certain rights to use and distribute this guide.

The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.


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