---
title: "The State Administration for Market Regulation released the \"Antitrust Compliance Guidelines for Internet Platforms\""
type: "News"
locale: "en"
url: "https://longbridge.com/en/news/275869498.md"
description: "On February 13th, the State Administration for Market Regulation released the \"Antitrust Compliance Guidelines for Internet Platforms,\" requiring platform operators with market dominance to avoid abusing their position and restricting market competition. The guidelines enumerate various restrictive behaviors, including setting exclusive cooperation terms, prohibiting cooperation with specific competing platforms, and implementing punitive measures, in order to maintain fair competition in the market and promote the healthy development of the platform economy"
datetime: "2026-02-13T08:28:24.000Z"
locales:
  - [zh-CN](https://longbridge.com/zh-CN/news/275869498.md)
  - [en](https://longbridge.com/en/news/275869498.md)
  - [zh-HK](https://longbridge.com/zh-HK/news/275869498.md)
---

> Supported Languages: [简体中文](https://longbridge.com/zh-CN/news/275869498.md) | [繁體中文](https://longbridge.com/zh-HK/news/275869498.md)


# The State Administration for Market Regulation released the "Antitrust Compliance Guidelines for Internet Platforms"

According to the Zhitong Finance APP, on February 13, the State Administration for Market Regulation released the "Antitrust Compliance Guidelines for Internet Platforms," which mentioned that platform operators with market dominance should avoid abusing their market position to restrict trading partners to only transact with them or their designated operators without justifiable reasons, or to prohibit transactions with specific operators, thereby excluding or limiting market competition.

Specifically, this includes the following methods: (1) setting exclusive cooperation clauses in platform rules such as merchant onboarding, platform services, content publishing, and application development, requiring platform operators to only cooperate with this platform or only publish specific goods or content on this platform; (2) requiring platform operators not to cooperate with specific competitive platforms or participate in promotional activities of specific competitive platforms through activity rules, cooperation agreements, in-site notifications, etc.; (3) implementing restrictions through punitive measures such as shop blocking, search ranking downgrades, traffic limitations, technical barriers, deposit deductions, fines, disqualification from promotional activities, delays in going live, differential rates, delayed payment terms, and reduced rating levels; (4) implementing disguised restrictions through incentive measures such as subsidies, discounts, promotions, traffic resource support, providing value-added services, and increasing rating levels.

## The original text is as follows:

**Notice from the State Administration for Market Regulation on Issuing the "Antitrust Compliance Guidelines for Internet Platforms"**

Market regulation bureaus (departments, commissions) of all provinces, autonomous regions, municipalities directly under the central government, and the Xinjiang Production and Construction Corps:

We are issuing the "Antitrust Compliance Guidelines for Internet Platforms" to you. Please carry out publicity and implementation in accordance with actual conditions.

State Administration for Market Regulation

January 28, 2026

**Antitrust Compliance Guidelines for Internet Platforms**

**Chapter 1 General Principles**

**Article 1 Purpose and Basis**

To support and guide platform operators in effectively preventing antitrust compliance risks, improving antitrust compliance management systems, protecting the legitimate rights and interests of relevant entities, maintaining fair market competition order, and promoting innovation and healthy development of the platform economy, these guidelines are formulated in accordance with the "Anti-Monopoly Law of the People's Republic of China" (hereinafter referred to as the "Anti-Monopoly Law") and other legal provisions.

**Article 2 Relevant Concepts**

The term "internet platform" referred to in these guidelines refers to a business organization form that creates value through transactions or other activities among interdependent bilateral or multilateral entities under specific rules provided by a carrier using network information technology.

The term "platform operator" referred to in these guidelines refers to operators that provide internet platform services such as operating venues, transaction matching, and information exchange to individuals, legal persons, and other market entities.

The term "platform operators" referred to in these guidelines refers to operators that provide goods or services (hereinafter collectively referred to as goods) within the internet platform.

The term "antitrust compliance risk" referred to in these guidelines refers to the possibility of legal liability, economic or reputational losses, and other negative consequences arising from the platform operator and its employees violating relevant provisions of the "Anti-Monopoly Law."

The term "antitrust compliance management" referred to in these guidelines refers to organized, planned, and full-process management activities aimed at preventing and controlling antitrust compliance risks concerning the operational management behaviors of platform operators and the performance of duties by employees **Article 3 Necessity of Compliance Management**

The network effects of internet platforms are significant, involving multiple parties such as platform operators, operators within the platform, consumers, and practitioners. Platform operators typically possess certain managerial attributes, strengthening market power through data and algorithms, technology, capital advantages, and platform rules, thereby influencing the competitive ecology of the platform. It is essential to strengthen antitrust compliance management.

Platform operators that violate the Antitrust Law will bear corresponding legal responsibilities, resulting in related business risks and credit risks. By enhancing antitrust compliance management, platform operators can avoid risks arising from engaging in monopolistic behavior, cultivate a good brand image, and establish core competitive advantages.

Enhancing antitrust compliance awareness among platform operators and improving antitrust compliance management systems will help raise the level and quality of competition, optimize resource allocation, improve operational efficiency, protect the legitimate rights and interests of multiple parties, promote the continuous optimization of the platform's competitive ecology, and achieve innovative development of the platform economy.

**Article 4 Basic Principles**

Platform operators should adhere to the following basic principles and refer to this guideline to carry out antitrust compliance management work, achieving fair rules, benevolent algorithms, and compliant competition:

(1) Targeted Principle. Identify, assess, and control compliance risks in a targeted manner based on factors such as the industry, business model, governance structure, and market competition conditions.

(2) Comprehensive Principle. Promote full-chain compliance before, during, and after events, achieving comprehensive coverage across business areas, departments, and employees, integrating decision-making, execution, and supervision, and building a collaborative and comprehensive compliance system.

(3) Penetrating Principle. Connect the headquarters of platform operators with branches, holding subsidiaries, etc., improve the guidance, coordination, and supervision mechanisms of the headquarters, and ensure that compliance management responsibilities are effectively implemented at all branches, achieving penetration across levels, businesses, and rule algorithms.

(4) Continuous Principle. Establish a long-term mechanism for antitrust compliance, ensuring the continuous and effective implementation of compliance management systems, preventing "one-time" or "phase-based" compliance, regularly assessing compliance operations, and timely updating and improving antitrust compliance management systems.

**Chapter 5 Overall Compliance Requirements**

Platform operators must earnestly assume the primary responsibility for antitrust compliance, improve antitrust compliance systems, strengthen antitrust compliance management, compete lawfully, operate in compliance, and must not engage in monopolistic behavior prohibited by the Antitrust Law using data and algorithms, technology, capital advantages, or platform rules.

**Chapter 2 Risk Identification**

**Section 1 Monopolistic Agreements**

A monopolistic agreement refers to agreements, decisions, or other collaborative actions that exclude or restrict competition. The Antitrust Law prohibits operators from reaching monopolistic agreements. Platform operators must comply with the Antitrust Law and the provisions prohibiting monopolistic agreements, avoiding reaching monopolistic agreements while providing platform services or conducting self-operated businesses, as well as organizing other operators to reach monopolistic agreements or providing substantial assistance.

To identify the risks of monopolistic agreements, platform operators typically first analyze whether the relevant behaviors fall under the circumstances specified in Articles 17, 18(1), and 19 of the Antitrust Law, and then analyze whether the aforementioned behaviors meet the conditions for non-prohibition or exemption as stipulated by the Antitrust Law **Article 6 Horizontal Monopoly Agreements**

Platform operators with competitive relationships should avoid reaching horizontal monopoly agreements through the following means to fix or change prices, restrict production (sales) volume, divide markets, limit new technologies (products), or jointly boycott transactions:

(1) Using meetings, phone calls, text messages, emails, shared documents, instant messaging tools, shared data pools, interoperability agreements, cloud storage platforms, artificial intelligence, etc., to communicate and exchange information regarding competitively sensitive information;

(2) Collecting and exchanging competitively sensitive information such as pricing models, commission rates, preferential policies, customer lists, traffic distribution mechanisms, as well as research and development, investment, production, marketing, and promotion strategies;

(3) Using data, algorithms, technology, platform rules, etc., to achieve coordinated actions in user classification, dynamic pricing, traffic distribution, product ranking, and other aspects.

Risk Example: Algorithmic Collusion Between Platforms

Platform operators with competitive relationships use algorithms to reach monopoly agreements through means such as communication, exchanging sensitive information, and coordinated actions. For example: Platform operators A and B have a competitive relationship, and A and B conspire through algorithms to unify pricing mechanisms, commission rates, etc., reaching a horizontal monopoly agreement that excludes or restricts market competition.

**Article 7 Vertical Monopoly Agreements**

Platform operators should avoid reaching vertical monopoly agreements with trading counterparts to fix resale prices or set minimum resale prices through the following means:

(1) Using big data analysis, artificial intelligence, and other technical means to automate the setting of resale prices;

(2) Using platform rules regarding interface calls, data usage, traffic distribution, promotional activities, store management, user services, etc., to unify resale prices;

(3) Using user profiles, predictive algorithms, etc., to directly or indirectly limit resale prices.

**Article 8 Organization and Substantial Assistance**

Platform operators should avoid organizing other operators within the platform to reach monopoly agreements or providing substantial assistance to achieve monopoly agreements through the following means:

(1) Organizing and coordinating communication between operators within the platform or with other operators through data sharing, issuing notices, signing agreements, etc.;

(2) Providing necessary support and creating key facilitative conditions for operators within the platform to obtain competitively sensitive information and achieve coordinated actions.

Risk Example: Organizing Assistance for Operators Within the Platform to Reach Monopoly Agreements

Platform operators organize and coordinate operators within the platform that have competitive relationships to reach horizontal agreements, or provide substantial assistance by offering necessary support and creating key conditions. For example: Platform operator A signs identical or similar price adjustment agreements with competing operators within the platform, during which the operators communicate and exchange competitively sensitive information, ultimately forming a unified pricing behavior that excludes or restricts market competition.

**Section 2 Abuse of Market Dominance**

Abuse of market dominance refers to behaviors by operators with market dominance that involve unfairly high pricing, unfairly low purchasing prices, selling below cost without justifiable reasons, refusing transactions, limiting transactions, tying sales, imposing other unreasonable conditions, or differential treatment The Anti-Monopoly Law prohibits operators with a dominant market position from engaging in abusive behaviors. It encourages platform operators with significant market share or market power to regularly assess whether they hold a dominant position in the relevant market. Platform operators must comply with the Anti-Monopoly Law and the Regulations on Prohibiting Abusive Market Dominance, avoiding abusive behaviors in the provision of platform services or the conduct of self-operated businesses.

To identify the risks of abusive market dominance, platform operators typically first define the relevant market, assess whether they hold a dominant position in that market, and whether they engage in relevant behaviors. They then consider whether there are legitimate reasons for such behaviors and whether these behaviors exclude or restrict market competition, specifically analyzing whether they constitute abuse of market dominance.

**Article 9 Factors to Consider for Market Dominance**

When assessing whether they hold a dominant position in the relevant market, platform operators can consider the following factors:

(1) The market share of the platform operator and the competitive situation in the relevant market. To determine the market share of the platform operator, factors such as transaction amount, transaction volume, sales revenue, number of registered users, number of active users, click-through rates, usage duration, number of operators within the platform, or other indicators' proportion in the relevant market should be considered, along with the duration of that market share. To analyze the competitive situation in the relevant market, factors such as the development status of the relevant market, the number of competitive platform operators and their market shares, competitive characteristics of the platform, degree of platform differentiation, economies of scale, potential competitive platform operators, innovation, and technological changes should be considered.

(2) The ability of the platform operator to control the market. This can include considerations of the diversity of online and offline business, vertical integration, and the ability of the platform operator to control upstream and downstream markets or other related markets, as well as the ability to hinder or influence other platform operators' entry into the relevant market, relevant business models, network effects, and the ability to influence or determine prices, traffic, or other transaction conditions.

(3) The financial and technical conditions of the platform operator. Factors such as investor situation, asset scale, sources of capital, profitability, financing ability, technological innovation and application capabilities, ownership of intellectual property, ability to manage and process relevant data, and the extent to which these financial and technical conditions can promote business expansion or consolidate and maintain market position should be considered.

(4) The degree of dependence of other operators within the platform on the platform operator in transactions. This can include considerations of the transaction relationships, transaction volume, transaction duration between other operators within the platform and the platform operator, lock-in effects, user stickiness, and the likelihood and cost of switching to other platforms.

(5) The ease or difficulty for other platform operators to enter the relevant market. Factors such as market access, platform scale effects, scale of capital investment, technological barriers, user multi-homing, user switching costs, ease of data acquisition, and user habits should be considered.

(6) Other factors based on the characteristics of platform economics that may indicate the platform operator has a dominant market position.

**Article 10 Unfair High Prices or Unfair Low Prices**

Platform operators with a dominant market position must avoid abusing their market dominance by selling goods at unfairly high prices or purchasing goods at unfairly low prices through the following means: (1) Charging operators on the platform significantly higher commissions, registration fees, handling fees, membership fees, technical service fees, information service fees, marketing promotion fees, and other charges than those charged by operators on other similar business platforms under the same or similar market conditions, or increasing the aforementioned charges to operators on the platform beyond a normal range while costs remain relatively stable;

(2) Charging operators on the platform unfairly high fees in disguised forms, such as by splitting service items or adding charging items;

(3) Paying operators on the platform prices for goods that are significantly lower than those charged by operators on other similar business platforms under the same or similar market conditions.

To determine whether market conditions are the same or similar, factors such as platform type, business model, transaction links, cost structure, and specific transaction circumstances can generally be considered.

Risk Example: Unfair High Prices on the Platform

Platform operators with market dominance abuse their market position through platform rules, technology, and algorithms to charge unfairly high fees to operators on the platform. For example, a platform operator with market dominance, A, continuously raises service fees beyond a normal range for several years while costs remain relatively stable, charging unfairly high fees to operators on the platform, harming their interests.

**Article 11: Selling Below Cost**

Platform operators with market dominance must avoid abusing their market position by selling goods or providing services at prices below cost without legitimate reasons, through excessive subsidies, cross-subsidies, etc., to eliminate or restrict market competition.

To analyze whether it constitutes selling below cost, the focus is generally on whether the platform operator is squeezing competitive platform operators out of the market by selling at prices below cost, and whether it is possible to gain improper benefits under unfair competition levels after squeezing competitive platform operators out of the market, harming fair market competition and consumers' legitimate rights and interests.

When calculating costs, the cost correlation and reasonableness among various related markets in the multi-sided market involved by the platform can be comprehensively considered.

Risk Example: Selling Below Cost on the Platform

Platform operators with market dominance abuse their market position without legitimate reasons by providing services at prices below cost through excessive subsidies and discounts that exceed reasonable limits, thereby eliminating or restricting market competition. For example, a platform operator with market dominance, A, provides free access and substantial subsidies to operators on the platform for a period that clearly exceeds commercially reasonable limits, and after competitive platform operators exit the relevant market, significantly raises access fees and related charges to gain improper benefits, harming fair market competition and consumers' legitimate rights and interests.

**Article 12: Refusal to Trade**

Platform operators with market dominance must avoid abusing their market position by refusing to trade with counterparties without legitimate reasons, thereby eliminating or restricting market competition through the following means:

(1) Stopping, delaying, or interrupting transactions with counterparties by removing goods, banning accounts, setting complex transaction processes, restricting traffic, closing interfaces, or interrupting data sharing;

(2) Refusing to trade with counterparties by setting unreasonable transaction conditions, service fees significantly higher than reasonable market levels, stopping application updates, interrupting data updates, or delaying the signing of cooperation agreements (3) Use traffic allocation algorithms, product release rules, etc., to restrict access to traffic and accept orders, substantially reducing the number of transactions with trading counterparts;

(4) Formulate unreasonable marketing, research and development, and other platform rules, or use discriminatory algorithms to set unreasonable restrictions and obstacles, making it difficult for trading counterparts to conduct transactions;

(5) By controlling specific data, models, application platforms, etc., that constitute essential facilities, refuse to trade with trading counterparts under reasonable conditions.

Risk Example: Blocking and Shielding

Platform operators with market dominance abuse their market position without justifiable reasons to block and shield trading counterparts at the application layer, transmission layer, network layer, etc., preventing them from entering relevant markets and excluding or restricting market competition. For example: Platform operator A, with market dominance, without justifiable reasons, restricts link redirection or port access, causing trading counterparts to be unable to conduct specific business or participate in market competition.

**Article 13: Limiting Transactions**

Platform operators with market dominance must avoid abusing their market position without justifiable reasons to limit trading counterparts to transact only with them or their designated operators, or to prevent them from transacting with specific operators, thereby excluding or restricting market competition:

(1) Set exclusive cooperation clauses in platform rules for merchant entry, platform services, content publishing, application development, etc., requiring operators within the platform to cooperate only with this platform or to publish specific goods or content only on this platform;

(2) Through activity rules, cooperation agreements, in-site notifications, etc., require operators within the platform not to cooperate with specific competitive platforms or not to participate in promotional activities of specific competitive platforms;

(3) Implement restrictions through punitive measures such as blocking stores, reducing search rankings, limiting traffic, technical obstacles, deducting deposits, fines, canceling participation in promotional activities, delaying launches, differential rates, extending payment terms, and lowering rating levels;

(4) Implement restrictions in disguise through incentive measures such as subsidies, discounts, promotions, traffic resource support, providing value-added services, and increasing rating levels.

Risk Example: "Choose One" Behavior

Platform operators with market dominance abuse their market position without justifiable reasons to force trading counterparts to choose between this platform operator and other competitive platform operators, and ensure the implementation of the aforementioned "choose one" behavior through punitive or incentive measures, thereby excluding or restricting market competition. For example: Platform operator A, with market dominance, without justifiable reasons, requires operators within the platform to promise not to cooperate with competitive platforms, and punishes those who do not comply with this promise through measures such as reducing search rankings, removing products, limiting traffic, and deducting deposits, restricting the freedom of choice of operators within the platform, resulting in effects that exclude or restrict market competition.

**Article 14: Tying or Adding Other Unreasonable Conditions**

Platform operators with market dominance must avoid abusing their market position without justifiable reasons to tie or add other unreasonable trading conditions, thereby excluding or restricting market competition: (1) Using difficult-to-select, change, or refuse format terms, pop-ups, and mandatory operational steps, requiring platform operators and consumers to use specified products when using their services;

(2) Forcing platform operators and consumers to accept other products through punitive measures such as search ranking downgrades, traffic restrictions, technical barriers, service shutdowns, and cancellation of authorizations;

(3) Forcing or indirectly forcing platform operators and consumers to participate in promotions, discounts, and preferential activities, accepting unreasonable matchmaking prices, or bearing costs and risks that should be borne by the platform operators;

(4) Adding unreasonable restrictions on transaction conditions and methods, service provision methods, payment methods and means, after-sales services, etc.;

(5) Forcing the collection of unreasonable fees such as technical service fees and traffic promotion fees that have not been explicitly disclosed, or charging unreasonable fees outside the transaction price through repeated charges;

(6) Forcing the collection of unnecessary user information or adding transaction conditions, transaction processes, and service items unrelated to the transaction subject.

Risk Example: "Lowest Price on the Internet"

Platform operators with market dominance abuse their market dominance without justifiable reasons, requiring platform operators to provide the lowest price on the internet, thereby excluding or restricting market competition. For example: a platform operator with market dominance, Party A, without justifiable reasons, requires platform operators to sell goods on that platform at prices not higher than those on other competitive platforms. If prices are lowered on other platforms, they must also lower prices on Party A's platform to the same or lower level and take measures to ensure compliance with these requirements, resulting in the exclusion or restriction of competition.

Platform operators without market dominance requiring platform operators to provide transaction conditions equal to or better than those of competitive platforms in terms of product prices, quantities, etc., may constitute a monopoly agreement.

**Article 15 Differential Treatment**

Platform operators with market dominance must avoid abusing their market dominance without justifiable reasons to implement differential treatment against platform operators and consumers with the same transaction conditions, thereby excluding or restricting market competition:

(1) Implementing differential standards, rules, and algorithms for platform entry, fee collection, marketing promotion, etc., for transaction counterparts with the same transaction conditions based on product categories, order quantities, rating levels, etc.;

(2) Utilizing data such as user preferences, transaction history, terminal devices, and usage habits to implement differential transaction prices, payment conditions, transaction methods, etc., based on analysis algorithms of payment ability, user stickiness, and price sensitivity.

The same transaction conditions referred to in the preceding paragraph mean that there are no substantial differences affecting the transaction among transaction counterparts in terms of transaction security, transaction costs, credit status, transaction stages, and transaction duration. Differences in privacy information, transaction history, individual preferences, and consumption habits of transaction counterparts obtained by platform operators during transactions do not affect the determination of the same conditions for transaction counterparts.

Risk Example: Platform Differential Treatment

Platform operators with market dominance abuse their market dominance without justifiable reasons to implement differential treatment in terms of prices, policies, etc., against platform operators and consumers with the same transaction conditions, thereby excluding or restricting market competition For example: Platform operator A has a dominant market position and, without justifiable reasons, charges different commission rates for transactions with platform operators of the same scale, goods, and credit, resulting in effects that exclude or restrict market competition.

**Article 16 Justifiable Reasons**

When assessing whether there are justifiable reasons as stipulated in Articles 11 to 15 of these guidelines, platform operators may consider the following factors:

(1) Within a reasonable period, for the development of other businesses on the platform, to promote new products entering the market, or to carry out promotional activities;

(2) In accordance with fair, reasonable, and non-discriminatory platform rules, or to prevent improper loss of interests for operators in the platform economy;

(3) Necessary to protect the legitimate rights and interests of trading counterparts, consumers, and practitioners, or to maintain a reasonable business model;

(4) In line with legitimate industry practices and trading habits, or necessary to enhance the utility or efficiency of goods;

(5) Necessary to protect intellectual property rights, trade secrets, personal information, or specific resource investments made for transactions;

(6) Necessary to ensure transaction security, data security, or network security;

(7) The existence of objective factors such as force majeure;

(8) Other reasons that can prove the legitimacy of the behavior.

Reasons that are consistent with the practices of competitive platform operators, align with consumer trends, protect market price stability, and maintain the overall integrity of the platform ecosystem generally do not fall under the justifiable reasons stipulated in Articles 11 to 15 of these guidelines.

**Section 3 Concentration of Operators**

Concentration of operators includes the following situations: (1) mergers of operators; (2) operators obtaining control over other operators through acquiring equity or assets; (3) operators obtaining control over other operators or being able to exert decisive influence through contracts or other means.

**Article 17 Reporting of Concentration of Operators**

If the concentration of operators meets the reporting standards stipulated in the "Regulations on Reporting Standards for Concentration of Operators" by the State Council, the operators shall report to the antitrust enforcement agency of the State Council in advance, and concentration shall not be implemented without reporting. For illegal implementation of concentration, the antitrust enforcement agency of the State Council will handle it according to law.

**Article 18 Compliance of Concentration of Operators**

Platform operators can refer to the "Antitrust Compliance Guidelines for Operators" and the "Antitrust Compliance Guidelines for Concentration of Operators" to identify, assess, and manage antitrust compliance risks related to concentration of operators, avoid concentrations that have or may have effects of excluding or restricting competition, and prevent legal liabilities arising from illegal implementation of concentration.

**Section 4 Abuse of Administrative Power to Exclude or Restrict Competition**

The "Antitrust Law" prohibits administrative agencies and organizations authorized by laws and regulations with public affairs management functions (hereinafter referred to as administrative subjects) from abusing administrative power to exclude or restrict competition. Platform operators can refer to the "Antitrust Guidelines for the Platform Economy" to avoid engaging in monopolistic behavior actively or passively under the coordination, promotion, or demands of administrative subjects. If platform operators believe that administrative agencies are abusing administrative power to exclude or restrict competition, they can report to the antitrust enforcement agency or legally apply for administrative reconsideration to the administrative reconsideration agency **Article 19: Monopolistic Behavior Coordinated and Promoted by Administrative Entities**

Platform operators should avoid actively participating in monopolistic behavior prohibited by the Anti-Monopoly Law that is coordinated or promoted by administrative entities, or using cooperation agreements, memorandums, etc., signed with administrative entities to implement monopolistic behavior.

**Article 20: Monopolistic Behavior Required by Administrative Entities**

When platform operators receive documents such as methods, decisions, announcements, notices, opinions, letters, meeting minutes, etc., required by administrative entities, they should pay close attention to whether the content of the documents poses antitrust compliance risks. If risks are identified, they should report to antitrust enforcement agencies as necessary.

**Chapter 3: Risk Management**

**Article 21: Risk Assessment**

Platform operators can establish a risk assessment indicator system based on the characteristics of their industry and market competition conditions, combined with their own operational scale, business model, and other factors, to comprehensively assess antitrust compliance risks. Platform operators are encouraged to implement classified and graded management based on risk assessments, taking different measures for different categories and levels of risks.

**Article 22: Risk Reminders**

Platform operators are encouraged to implement tiered reminders for employees based on their positions and levels. Targeted risk reminders should be conducted according to the different risks faced by employees in different positions, levels, and work scopes. Key personnel for risk reminders include:

(1) Legal representatives, directors, and senior management;

(2) Heads of major business units and new business leaders;

(3) Personnel who may come into contact with competitive platform operators or upstream and downstream operators;

(4) Personnel in departments responsible for sales, procurement, pricing and business policy formulation, merger management, sales network management, and liaising with industry associations who are aware of competitive sensitive information;

(5) Personnel who have previously worked for competitive platform operators and may be aware of their competitive sensitive information;

(6) Personnel responsible for corporate merger projects;

(7) Other high-risk personnel for antitrust compliance.

**Article 23: Preemptive Risk Prevention**

Platform operators can conduct antitrust risk identification and assessment for relevant matters before formulating rules, designing algorithms, signing agreements, engaging in business negotiations, making investments and acquisitions, adjusting business models, and organizing marketing activities, and provide risk reminders in accordance with Article 22 of these guidelines.

**Article 24: In-Process Risk Prevention**

During operations, platform operators should timely update their risk assessment indicator system and reassess antitrust compliance risks based on changes in laws and regulations, industry conditions, market structure, and business layout, and propose compliance suggestions regarding the risk prevention work of platform operators.

**Article 25: Post-Event Risk Prevention**

Platform operators can review antitrust compliance risks after completing marketing activities, investment transactions, and business collaborations, and provide feedback on strengthening and improving their own risk prevention work to prevent and mitigate antitrust compliance risks.

**Article 26: Review of Platform Rules**

Platform operators can conduct a comprehensive review of platform rules, focusing on account management rules, end-user policies, agreements and management measures for platform operators, cooperation agreements with third-party service providers, traffic distribution rules, promotional activity policies, etc., to avoid antitrust compliance risks **Article 27 Algorithm Screening**

Platform operators may conduct targeted screening and dynamic monitoring of various pricing algorithms, recommendation systems, sorting logic, advertising strategies, and other core algorithm models used within the internet platform, focusing on issues such as discriminatory design, unfair trading orientation, excessive price adjustments, uniform pricing pushes, and strategic algorithm sharing, to avoid antitrust compliance risks.

Platform operators are encouraged to combine technical means with manual reviews to ensure algorithm logic is transparent and explainable, avoiding algorithmic black boxes that disrupt market competition, harm consumer interests, and damage social public interests. Platform operators are encouraged to establish mechanisms for algorithm iteration and correction, promptly taking down and adjusting relevant algorithms upon discovering risks, while maintaining complete audit records.

**Article 28 Cooperation with Investigations**

Platform operators and their employees, as well as operators within the platform, must cooperate with antitrust enforcement agencies' investigations and truthfully provide evidence materials requested by the antitrust enforcement agencies, avoiding the following behaviors that refuse or obstruct investigations:

(1) Refusing or obstructing enforcement personnel from entering business premises;

(2) Refusing to provide relevant documents, materials, information, or access permissions;

(3) Refusing to answer questions;

(4) Concealing, destroying, or transferring evidence;

(5) Providing misleading or false information;

(6) Other behaviors that refuse or obstruct antitrust investigations.

**Article 29 Compliance Rectification**

Platform operators must rectify according to the requirements of the antitrust "three letters and one notice," such as "Reminder and Urging Letter," "Interview Notice," "Case Investigation Notice," and "Administrative Penalty Decision," and should pay attention to timely submitting rectification plans, orderly advancing rectification work, and submitting rectification reports on time. Platform operators may take appropriate measures to evaluate the effectiveness of rectification, continuously improve compliance management systems, and enhance compliance management frameworks.

Platform operators may proactively disclose rectification measures and results to the public and accept supervision.

**Article 30 Compliance Incentives**

Platform operators must establish and effectively implement a comprehensive antitrust compliance management system. When encountering antitrust investigations, platform operators may apply for compliance incentives from antitrust enforcement agencies based on the provisions of the "Antitrust Compliance Guidelines for Operators." Antitrust enforcement agencies may consider the construction and implementation of the platform operator's antitrust compliance system and grant necessary compliance incentives at their discretion.

**Chapter 4 Compliance Assurance Mechanism**

**Article 31 Compliance Management Institutions**

Antitrust compliance management institutions are responsible for coordinating, organizing, and promoting antitrust compliance management work, which can be specially established or undertaken by relevant departments. Platform operators are encouraged to provide necessary resources for compliance management institutions to independently perform their duties, ensuring effective implementation of antitrust compliance management. Platform operators are encouraged to establish a Chief Compliance Officer.

Headquarters of platform operators may require branches, holding subsidiaries, and others to cooperate in conducting risk assessments, reporting investigations, supervision checks, and problem rectification related to antitrust compliance management.

**Article 32 Compliance Reporting**

Platform operators are encouraged to establish an antitrust compliance reporting mechanism, where the head of antitrust compliance management listens to reports from the leading department on compliance management implementation and compliance risks, and regularly reports the status of antitrust compliance management to the main responsible person of the platform operator, promptly reporting significant compliance risks related to antitrust issues The compliance management leading department can organize business and functional departments to report on the antitrust compliance work and compliance risks of their departments.

Encourage platform operators' headquarters to regularly listen to reports from branches, holding subsidiaries, and other compliance management leading departments on the implementation of antitrust compliance management and major risks, collect the materials and information needed for antitrust compliance management work, and timely grasp compliance risk matters.

**Article 33 Compliance Training**

Encourage platform operators to invest effective resources to establish an antitrust compliance training mechanism, incorporate antitrust compliance training into employee training plans and regular compliance training mechanisms, and conduct targeted training based on the compliance management requirements of different positions. Encourage platform operators to establish a compliance training ledger, timely update training content in accordance with relevant provisions of antitrust law, and regularly evaluate training effectiveness.

**Article 34 Compliance Assessment**

Encourage platform operators to establish and improve personnel assessment and reward and punishment mechanisms for antitrust compliance, using assessment results as an important basis for the performance evaluation of employees and their departments, motivating and urging employees to consciously comply with antitrust compliance management requirements. For personnel or departments with unsatisfactory assessment results or involved in complaints and reports, corresponding corrective measures should be taken.

The headquarters of platform operators can evaluate and guide the antitrust compliance management work of branches and holding subsidiaries.

**Article 35 Compliance Supervision**

Encourage platform operators to establish a mechanism for handling and feedback on antitrust compliance reports, actively respond to antitrust compliance complaints and reports from employees, platform operators, consumers, and practitioners, and organize investigations.

Encourage platform operators to establish an external evaluation mechanism involving platform users such as platform operators, consumers, practitioners, and independent third parties, consciously accept social supervision, and continuously improve platform governance rules.

**Article 36 Information Technology in Compliance Management**

Encourage platform operators to strengthen the information technology construction of compliance management, embed compliance requirements and risk prevention mechanisms into business information processes, support business and functional departments in conducting information technology compliance management for their daily work, enhance process control and operational analysis of compliance with management behaviors, record and preserve relevant information, and improve compliance work efficiency.

**Chapter 5 Supplementary Provisions**

**Article 37 Effectiveness of the Guidelines**

These guidelines are special antitrust compliance guidelines for internet platforms, aimed at providing general guidance for platform operators' antitrust compliance and are not mandatory.

Platform operators and relevant industry associations can refer to these guidelines, establish and improve antitrust compliance systems based on the provisions of antitrust laws, regulations, and guidelines, and optimize compliance work systems according to their own characteristics.

**Article 38 Interpretation of the Guidelines**

These guidelines are interpreted by the State Administration for Market Regulation.

This article is compiled from the official website of the "State Administration for Market Regulation," edited by Xu Wenqiang of Zhitong Finance

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