Analysis of the Impact of the New Public Fund Sales Fee Regulations on the Public Fund Industry

The Measures for the Administration of Sales Fees of Publicly Offered Securities Investment Funds issued by the CSRC mark the conclusion of the “three-step” fee reform for public funds, which will have a profound impact on the industry’s profit model and competitive landscape [1][6].

• Active Equity-Oriented Funds:
  Subscription fee cap reduced from 1.2% to 0.8% [1]
• Hybrid Funds:
  No more than 0.5%
• Index Funds and Bond Funds:
  No more than 0.3% [1]
• ETFs and Bond Funds:
  Sales service fees halved [1]
• Holding Incentive:
  Investors holding funds for more than one year will no longer be charged sales service fees [1]
• Redemption Fees:
  Should be fully included in fund assets [8]

According to estimates, the new regulations will reduce sales fees across the industry by

, saving investors over annually. Combined with the results of the first two phases of fee reduction, the cumulative benefit to investors exceeds [6].

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The revenue structure of traditional channels will undergo fundamental changes. According to estimates of sales channel revenue in 2023 (approximately 73.8 billion yuan), the breakdown is as follows:

• Subscription/purchase fees account for 8%
• Redemption fees 5%
• Sales service fees 34%
• Customer maintenance fees 53%
  [12]

After the implementation of the new regulations:

• Subscription/purchase fee revenue will drop significantly
  : the fee cap is directly cut by 30%-50% [1][8]
• Sales service fee revenue will be halved
  :
  • Money market fund sales service fees are unified from 0.25%-0.4% to 0.15%, and third-party sales institutions holding hundreds of billions of yuan in money market funds will directly lose tens of millions of yuan in net income annually [8]
  • Non-monetary products held for more than one year will no longer charge sales service fees, directly cutting off a large part of the stock income of securities firms [8]
• Redemption fees are included in fund assets
  : sales channels completely lose this part of income [8]

Traditional Model	New Model
Fee based on sales volume	Fee based on asset holding scale
Product sales-oriented	Provide allocation and solutions
Transaction relationship	Professional service and companionship [9]

The new regulations set differentiated upper limits on the payment ratio of customer maintenance fees, directly guiding the industry to transform from scale expansion to quality improvement [7].

• Securities Firm Sub-account Commissions
  : In 2024, the fund sub-account commission income of securities firms was 11 billion yuan, a 35% decrease from 2023 and only 51% of that in 2021 [12]
• Income from Agency Sales of Financial Products
  : The net income from agency sales of financial products of listed securities firms in 2024 was 9.033 billion yuan, a 17.71% decrease from 10.976 billion yuan in 2023 [12]

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The new regulations completely curb the impulse for initial public offerings (IPOs) of equity-oriented funds, and redemption fees are no longer available to sales institutions, so the “heavy IPO + high turnover” operation model is declared ended [8]. Channels focus on low-fee, standardized ETFs [8].

:

• The IPO ecosystem is most affected, with a significant drop in subscription/purchase fee income
• But it has the advantage of retaining customer resources (bank holding scale accounted for 46% at the end of 2024) [12]
• Need to accelerate the construction of wealth management capabilities and find new growth points through the “AUM (Assets Under Management) is King” logic [14]

:

• High-risk appetite securities firm Class C share sales service fee income is cut off by a large part [8]
• The sharp decline in sub-account commission income forces securities firm research institutes to improve investment research capabilities
• Forced to accelerate the transformation to the buyer advisor model [9]

:

• Most severely affected
  :
  • The model of channels forcing managers to set up different DEF shares is abolished [8]
  • Money market fund sales service fees are unified at 0.15%, and institutions holding hundreds of billions of yuan in money market funds lose tens of millions of yuan in net income annually [8]
  • The profit model of baby products is completely disrupted [8]

The new regulations promote the industry’s transformation from “seller sales” to “buyer advisor”:

Seller Sales Model	Buyer Advisor Model
Maximize own interests	Charge fees related to customers’ existing asset scale, aligned interests [13]
Chase hotspots, sell	From customer’s perspective, investor-oriented [13]
“Funds make money, but fund investors don’t”	Advisor customers have an average holding period of 688 days, and chasing ups and downs decreases by 40% [11]
7% of independent customers have losses over 20%, while only 0.7% of advisor customers [11]

:

• CICC Wealth’s buyer advisor holding scale
  exceeds 100 billion yuan
  , serving over 400,000 people cumulatively [13]
• “ETF50” has accumulated over 63,000 signed customers, and the holding scale increased by
  291%
  compared to the same period last year [13]

---

• Research capability becomes core competitiveness
  : Fee reduction forces fund companies to improve investment research capabilities
• Product structure optimization
  : ETFs and low-fee products are given higher priority [8]
• Sales strategy adjustment
  : Shift from over-reliance on channels to enhancing own investment research and brand influence

• Cost reduction
  : Investment costs drop significantly, saving over 300 billion yuan annually [6]
• Behavior correction
  : Buyer advisor customers’ chasing ups and downs decreases by 40%, and average holding period is significantly extended [11]
• Income improvement
  : Over 90% of advisor customers have positive returns, and extreme loss risk is only 0.7% (7% for independent customers) [11]

---

1. Industry concentration may increase
   : Leading institutions with strong investment research capabilities and buyer advisor service capabilities will gain larger market share

2. Fee competition will intensify
   : Channels may further engage in price wars below regulatory caps

3. Technology empowerment becomes key
   : Securities firms accelerate the application of large models in customer service, enhancing online service capabilities through AI technology [12]

4. Interest mechanism restructuring
   : Shift from “fund scale-oriented” to “investor return-oriented” [1]

Through the mechanism design of “increasing short-term speculation costs and reducing long-term investment costs” [1], the new regulations will guide the public fund industry to transform from scale-driven to

, and finally achieve and among investors, sales channels and asset management institutions [1].

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[1] Reuters - “China to cut fees on $4.9 trln mutual fund industry to promote investment” (https://www.reuters.com/sustainability/boards-policy-regulation/china-cut-fees-49-trln-mutual-fund-industry-promote-investment-2025-09-06/)

[6] Yicai - “让利超500亿！公募基金费率改革送出’新年大礼包’” (https://www.yicai.com/news/102983974.html)

[7] Sina Finance - “基金新规正式实施：公募基金费率全面优化，简化赎回费收费安排” (https://finance.sina.com.cn/roll/2025-12-31/doc-inhetcuh3576264.shtml)

[8] Trust Website - “《公募基金销售费用新规（征求意见稿）》解读：变革” (https://www.usetrust.com/Information/Details.aspx?i=137234)

[9] The Paper - “中国证券行业2025年十大新闻” (https://www.thepaper.cn/newsDetail_forward_32273430)

[11] Nanfang+ - “从短期博弈到长期共赢，'买方投顾’藏着怎样的投资新体验？” (https://www.nfnews.com/content/46NdGQd5ym.html)

[12] KPMG - “二零二五年中国证券业调查报告” (https://assets.kpmg.com/content/dam/kpmg/cn/pdf/zh/2025/08/mainland-china-securities-survey-2025.pdf)

[13] 21st Century Business Herald - “突破千亿，中金财富买方投顾何以领跑？” (https://www.21jingji.com/article/20250807/herald/3accf433be2532fdc4111ea4fe0a84ba.html)

[14] Xinhuanet - “2025银行业重塑’指挥棒’ 多方合力绘就韧性之年” (http://www.xinhuanet.com/20251226/7c815ef38e4449de99dfca7bf3420f9d/c.html)