China Regions Tighten Life Insurance ‘Dual Recording’ Rules

Multiple regions across China are refining the “dual recording” rules for life insurance sales, requiring insurers to capture audio and video documentation of key sales process steps to strengthen consumer protection and curb sales misconduct. The measures, issued by local financial regulatory authorities in Shanxi, Xinjiang, and Dongguan, build on a national framework established in 2017 and represent a significant escalation in regulatory oversight of the insurance industry, according to Xinhua News.

Background: The “Dual Recording” System

The “dual recording” system requires insurance companies and intermediaries to use synchronized audio-video recording technology to capture and preserve critical steps in the insurance sales process. This includes verifying the salesperson’s identity, disclosing product terms, explaining policy conditions, and recording the customer’s acknowledgment and signature. The system was first established nationally in 2017 when the China Insurance Regulatory Commission issued the “Interim Measures for the Traceability Management of Insurance Sales Behavior.”

Since then, the regulatory framework has evolved considerably. In September 2023, the National Financial Regulatory Administration issued the Insurance Sales Behavior Management Measures, effective March 1, 2024, which codified comprehensive sales behavior regulation across pre-sale, during-sale, and post-sale stages. More recently, the “Financial Institution Product Suitability Management Measures,” effective February 1, 2026, added requirements for matching products with customer risk tolerance levels.

Regional Refinements in 2026

Since the beginning of 2026, multiple local financial regulatory authorities have issued documents to further refine “dual recording” requirements, covering scope of application, recording content, and quality inspection standards.

Shanxi Province issued a notice in July 2026 requiring insurance companies and intermediaries to record key sales process steps via synchronized audio-video for life insurance products with insurance periods exceeding one year sold to natural persons, with the insured’s consent. The Shanxi notice sets implementation for April 1, 2027, with a transition period beginning from the notice’s issuance.

Xinjiang issued its notice in March 2026, clarifying sales personnel’s explanation obligations. The Xinjiang notice requires salespeople to inform buyers of the underwriting insurance institution name, product name, insurance liability, and other key information. It also specifies rigorous quality inspection requirements: monthly sampling rates of no less than 30% of recorded policies, at least 60% for special groups, and 100% for investment-linked products or policies for insureds aged 60 and above.

Dongguan in Guangdong Province issued its notice in February 2026, focusing on audio-visual materials management and retention. The Dongguan notice mandates that recordings must be authentic, complete, and continuous—no editing is allowed after recording—and that recording time must be displayed in the video. Retention periods extend at least 10 years from contract termination, or at least 2 years after dispute resolution for contested cases.

Industry Response and Expert Analysis

Insurance companies are already adapting to the stricter requirements. “We are upgrading our business systems, improving recording and audio-visual material storage conditions, and strengthening sales personnel training to ensure relevant requirements are implemented at the sales frontline,” a customer manager at a South China life insurance company told Economic Daily.

Experts say the refinements reflect a maturing regulatory approach. Xu Xin, Director of the Insurance Department at Capital University of Economics and Business, described the local regulatory documents as “a necessary step to implement higher-level regulations and fill in implementation details based on local conditions,” noting that the regulatory focus is shifting from “whether it exists” to “how detailed and practical it is.”

Wang Xuanhe, Director of the Insurance Department at Dongbei University of Finance and Economics, emphasized the consumer protection dimension: “‘Dual recording’ management will push sales personnel to clearly explain what should be explained, allowing consumers to make choices based on full information.”

Implications for the Industry

The tightening of “dual recording” rules carries significant implications for China’s life insurance sector. Wang Xuanhe noted that “life insurance sales will place more emphasis on truthful explanation and full-process responsibility,” adding that “business models purely driven by sales results will face more constraints.”

Industry observers also point to growing competitive pressures. Larger institutions with greater technological and resource advantages are better positioned to complete system upgrades, while smaller institutions may face higher compliance costs. Some channels may experience short-term impacts on premium growth as institutions adjust to the new requirements.

Looking ahead, technology is expected to play an increasingly important role in balancing compliance costs with business efficiency. Xu Xin noted that AI-powered intelligent quality inspection and remote “dual recording” will become important tools for institutions navigating the new regulatory landscape.

What to Watch

As the April 2027 implementation date for Shanxi’s notice approaches, and as other regions continue to refine their rules, the insurance industry will be watching closely for:

• Further regional notices that may set even more detailed requirements
• How smaller insurers adapt to rising compliance costs
• The pace of adoption of AI-powered quality inspection and remote recording technologies
• Whether the stricter rules lead to measurable improvements in consumer satisfaction and dispute resolution

The cumulative effect of these regulatory refinements signals a clear direction: China’s life insurance market is moving toward a more transparent, consumer-centric model where every sales interaction is documented, verifiable, and accountable.