Beijing, November 16, 2025 — China’s State Administration for Market Regulation (SAMR) has released a draft Antitrust Compliance Guide for Internet Platforms that highlights new and emerging monopoly risks and offers detailed compliance instructions for platform operators amid evolving business models and intensified competitive pressures.
New Monopoly Risks in Platform Behaviour
The draft guidance highlights eight categories of new forms of potential monopoly conduct that have become increasingly prominent in the platform economy. SAMR identifies problems such as excessive subsidies, cross-subsidisation, and below-cost pricing by dominant platforms, warning that selling below cost without a valid justification may constitute abusive conduct.
The document also stresses that platforms may not require merchants to take part in promotions or assume costs that should be borne by the platform.
The guidance further clarifies that forcing merchants to provide the lowest prices across all platforms can raise antitrust concerns. According to the draft, a dominant platform may not, without legitimate reason, demand that merchants offer all-network lowest prices, and even non-dominant platforms may trigger vertical-agreement risks by imposing such requirements.
On “blocking and disabling,” the draft provides one of its most detailed clarifications. SAMR lists restrictive practices—such as limiting traffic, closing interfaces, interrupting data sharing, halting app updates, or using discriminatory algorithms—that may constitute refusal to deal. It also notes that these forms of conduct can appear at the application, transmission or network layer, reflecting the complexity of ecosystem-wide technical restrictions.
Technology-Driven Risks and Algorithmic Conduct
Recognising the growing influence of cloud computing, big data, and AI, the draft outlines the ways in which algorithms, data, and interfaces can facilitate restrictive or exclusionary behaviour. It details how algorithmic tools may enable collusion, information exchange, or resale-price maintenance, and sets out specific risk scenarios for refusal to deal, tying, discriminatory treatment, and the use of technical measures by dominant platforms.
The guidance calls for strengthened algorithm governance, combining rule reviews with algorithmic screening, dynamic monitoring, and manual oversight. It encourages platforms to establish transparency and correction mechanisms to prevent algorithmic distortion of competition.
Platform Ecosystems and Market Power
The draft incorporates platform “ecology” into the antitrust framework, emphasising that platforms operate as multi-sided ecosystems with both commercial and rule-setting roles. SAMR stresses that platform operators influence businesses, gig-economy workers, and consumers, and that maintaining a healthy platform ecology is a core antitrust objective.
The guidance elaborates on how to assess platform market power, including platform-ecosystem size, operator dependence on platform channels, and the effects of cross-market integration, multi-business models, and online-offline linkages.
Source: https://www.samr.gov.cn/xw/mtjj/art/2025/art_d6de65ed742841978786fb87303fd080.html
