On 18 December 2025 the State Administration for Market Regulation and the Cyberspace Administration of China issued Order No. 116, the Measures for the Supervision and Administration of Online Trading Platform Rules, effective 1 February 2026. It follows the live commerce supervision measures as another sectoral rule treating “platform governance” as an independent regulatory object.
What the Measures regulate
The object is “platform rules” — the rules a platform operator makes and amends to govern the conduct of merchants and consumers. It is concerned not with individual transactions but with how the rules themselves are formed and operated.
From the published provisions, the core requirements concentrate on three steps:
First, continuous publication. A platform should continuously publish its platform rules, or a link to them, prominently on its website and app homepage, ensuring merchants and consumers can conveniently and completely read and download them.
Second, public consultation. When making or amending platform rules, a platform should publicly consult on its homepage, reserving adequate time and providing technical support so all parties can express views promptly and fully.
Third, consolidation and feedback. A platform should comprehensively and truthfully consolidate the comments received, absorb and adopt reasonable ones, and give reasonable grounds for those not adopted.
Failure to publish or consult as required is punishable under Article 81 of the E-Commerce Law.
Why “procedure” itself became the object
Platform rules have a quasi-legislative character — they determine who may trade, how, and how violations are handled, directly affecting merchants’ rights and obligations. Earlier supervision focused on whether rule content was unlawful; the Measures move supervision upstream to how rules are produced.
The logic is clear: where platform rules materially affect merchants, the process of making them needs to be participatory and accountable. Without procedural constraints, rules can become a tool for a platform to unilaterally shift risk.
What it means for AI service companies
First, if your product is itself a platform, rule-making needs to be compliant. Products with platform characteristics — AI app distribution, model call marketplaces, creator communities — should build publication and consultation processes for their user terms, community rules and enforcement rules.
Second, if you trade on a platform, watch the amendment process. When a platform changes traffic allocation, commission rates or penalties by amending its rules, merchants can check whether the amendment followed the consultation and publication requirements as a basis for asserting rights. See our commercial contracts service.
Third, AI-generated content labelling will enter platform rules. Platform rules must carry content governance duties, including labelling management for AI-generated synthetic content. This connects with the Measures for Labelling AI-Generated Synthetic Content and the requirements on digital-human streamers. See our notes on labelling enforcement and the live commerce supervision measures.
Alignment with the live commerce measures
Orders No. 116 and No. 117 (live commerce supervision measures) are closely sequenced, together forming a procedural constraint framework for the platform economy. The former governs “how rules are made”, the latter “how a specific business model operates”. Companies spanning both e-commerce and content should read the two together.
Raising platform rules from “internal document” to “regulated public document” is the most important change here. For platform-type AI companies, institutionalising the rule-making process early is the best way to avoid being on the back foot in disputes.
This article is based on the Measures for the Supervision and Administration of Online Trading Platform Rules (SAIC and CAC Order No. 116) and public information. It is for general reference only and does not constitute legal advice.