China’s market regulator has published a long-awaited compliance guide aimed squarely at internet platforms, telling companies to harden internal controls against a raft of antitrust risks tied to data, algorithms, platform rules and capital power. The document frames platforms as complex multi‑sided markets in which operators can amplify market power through technical design and governance choices, and urges firms to adopt targeted, comprehensive and continuous compliance systems.
The guidance lays out detailed red lines. It warns against horizontal and vertical cartel conduct — including price‑fixing, information exchanges, and algorithmic tacit collusion — and explicitly calls out “choose‑one” exclusivity practices as a form of market‑power abuse when imposed without justification. It also enumerates classic abuses of dominance: unfair high or low pricing, refusal to deal, tying and bundling, discriminatory algorithms and punitive measures such as de‑ranking or account suspension.
Importantly, the document asks platforms to assess market dominance by looking beyond simple market share: regulators should consider transaction values and volumes, user stickiness, control over data and interfaces, financing and technical edge, and the difficulty rivals face in entering the market. The guide gives operational advice too — risk‑assessment frameworks, algorithm screening, platform‑rule audits, compliance training, chief compliance officers and audit trails for algorithm changes.
Although the guide is explicitly non‑binding, it is cast as an industry playbook: firms are encouraged to preemptively remediate problems, cooperate with investigations and seek rewards for genuine compliance. The regulator reiterates existing enforcement tools — from warning letters and interviews to investigations and fines — and tells platforms to treat remedial “three‑book‑and‑one‑letter” measures seriously when they are required.
For merchants and consumers the guidance promises clearer protections: it targets coercive exclusivity that forces sellers to pick a single marketplace, curbs manipulative algorithmic sorting that can distort visibility, and restricts below‑cost subsidy strategies that aim to squeeze rivals. For platforms the immediate consequence will be legal and operational costs as firms redesign rules, audit models and document decision‑making chains.
The timing matters. Beijing’s move follows years of stepped‑up scrutiny of tech giants — from high‑profile probes and fines to tightened merger reviews — and complements other regulatory pillars such as data‑security and consumer‑protection rules. The new guide signals that antitrust supervision will increasingly focus on the technical levers of platform power, not just corporate filings and pricing schedules.
Foreign investors and overseas platforms should take note: the guidance widens the scope of scrutiny to include interfaces, API access, data sharing and algorithmic design, areas where cross‑border operations and cloud‑based services intersect with national supervision. Compliance will require more than policy memos; it will demand engineering controls, cross‑border legal strategies and sustained documentation of why product or pricing choices are competitively benign.
In short, the guide maps out how Beijing expects platform conduct to be governed in practice. Companies that treat it as a blueprint for enforcement will face operational upheaval; those that integrate its prescriptions early can turn compliance into a competitive advantage by signaling reliability to regulators, merchants and consumers alike.