Beijing, November 24, 2025 — China’s State Administration for Market Regulation (SAMR) has released for consultation a draft Internet Platform Antitrust Compliance Guide outlining eight high-risk monopoly scenarios for digital platforms, including algorithmic collusion, “choose-one-of-two” exclusivity, unfair high pricing, below-cost sales, discriminatory treatment and all-network lowest-price mandates.
The draft guidance aims to help platform operators identify and prevent conduct that could breach China’s Anti-Monopoly Law, setting clearer behavioural boundaries and strengthening compliance in a sector where enforcement has surged in recent years.
Compliance Focus
SAMR emphasised that the eight scenarios — platform-to-platform algorithmic coordination, organising or assisting in agreements among platform merchants, unfairly high prices, below-cost pricing, blocking or de-platforming rivals, forced exclusivity, all-network lowest-price requirements and discriminatory treatment — are not automatic infringements.
However, the agency said they represent recurring risks observed in digital-platform enforcement and should guide operators’ internal risk assessments.
The draft also encourages platforms to undertake algorithm audits, rule reviews and dynamic monitoring, and to avoid actions that could facilitate collusion among merchants.
Governance and Prevention
SAMR proposes that platform operators create full-chain compliance systems covering risk assessment, internal alerts, pre-decision reviews, ongoing monitoring and post-event evaluation.
The guidance highlights the need for oversight of platform rules, including account policies, traffic-allocation rules, promotional frameworks and third-party cooperation agreements.
On algorithms, SAMR calls for targeted screening, monitoring and corrective mechanisms to prevent risks such as tacit algorithmic coordination or discriminatory pricing.
Cooperation with Investigations
Under the draft, platforms must cooperate fully with antitrust investigations, provide accurate information, and avoid obstructing enforcement. When required to implement remedies, platforms should submit rectification plans promptly and track effectiveness.
SAMR said the guidance aligns with broader national objectives to promote innovation in platform markets while maintaining a fair, competitive environment.
It framed the guidance as part of efforts to “stabilise expectations and boost development confidence,” particularly as platform businesses navigate rapid technological change and increasing scrutiny over data and algorithm governance.
Source: https://www.samr.gov.cn/xw/mtjj/art/2025/art_3f0e31d26433455e82341f28347fc394.html
