China's National Financial Regulatory Administration finalizes asset management trust rules with investor and portfolio limits

China's National Financial Regulatory Administration has finalized the Administrative Measures for Asset Management Trusts and published an accompanying explanation, following the consultation launched in October 2025. The measures govern trust companies' asset management products throughout their life cycle and define them as privately offered products limited to 200 qualified investors. Higher-risk products face stricter investor eligibility requirements and minimum investment amounts. Except for certain qualifying products, investment in a single asset or another asset management product cannot exceed 25% of a trust product's net assets. Trust companies must retain management responsibility and manage and account for each product separately. The rules prohibit unlawful conduit business and fund pooling, while open-ended trust products cannot invest in nonstandard assets. Distribution through sales agents is restricted to trust companies, commercial banks, insurers and securities firms. Products must match investors' risk tolerance, and guarantees of principal or returns are prohibited. Risk controls require sufficient impairment provisions at product level and quarterly risk classification of financial assets. Trust companies must also strengthen concentration and liquidity risk management and disclose product information under applicable requirements. For existing business, firms must identify products requiring remediation, establish schedules and progressively reduce affected business. Selected requirements, including investor concentration and portfolio investment limits, distinguish between new and existing business for remediation purposes. Remediation progress will inform supervisory classification.