Key Points
- The China Securities Regulatory Commission (CSRC) has issued new “Supervisory Rules for Board Secretaries of Listed Companies,” effective May 24, 2026, prohibiting board secretaries from concurrently holding other core management roles (manager, deputy manager in charge of business operations, financial head).
- Almost 70% of A-share listed banks (approximately 30 out of 42) currently violate these new rules, as their board secretaries also hold positions like Deputy Governor, CFO, or Chief Risk Officer.
- The rules aim to address conflicts of interest and improve governance, information disclosure, and compliance by ensuring a separation of duties.
- Banks have a transition period through the end of 2027 (over 18 months) to comply, but must navigate dual regulatory approvals and find specialized talent for these standalone roles.
- This overhaul is expected to lead to more objective oversight and transparent reporting, enhancing the capital market credibility of Chinese banks in the long term.
- Total A-share Listed Banks: 42
- Banks Requiring Personnel Adjustments: ~30 (71%)
- Banks Already in Compliance: ~12 (29%)
- Primary Conflict Type: Deputy Governor, CFO, or Chief Risk Officer concurrently serving as Board Secretary
On April 24, 2026, China’s financial establishment made a move that’s about to send shockwaves through the banking sector.
The China Securities Regulatory Commission (Zhongguo Zhengquan Jiandu Guanli Weiyuanhui 中国证券监督管理委员会) officially released the “Supervisory Rules for Board Secretaries of Listed Companies”—the first-ever dedicated regulatory framework for board secretaries—effective May 24, 2026.
And here’s the kicker: nearly 70% of A-share listed banks are about to face major personnel reshuffles because of it.
What Changed: The New Rules That Are Forcing Bank Restructuring
The regulatory shift seems simple on the surface, but it’s actually a major governance overhaul.
Under the new framework, a Board Secretary (Dongshi Hui Mi Shu 董事会秘书) cannot concurrently serve as:
- A manager
- A deputy manager in charge of business operations
- A financial head
That last part is crucial because it directly contradicts how most Chinese banks currently operate.
Historically, board secretaries in China’s banking system have routinely held multiple roles simultaneously. This wasn’t just common—it was basically the standard playbook. But the CSRC just decided to flip that script entirely.
Why does this matter?
The CSRC identified a governance problem: when one person wears too many hats, conflicts of interest naturally emerge. A board secretary managing information disclosure, governance supervision, and investment/financing compliance while simultaneously running day-to-day operations creates obvious friction.
The Banking Industry Reality: 70% of Listed Banks Have Board Secretary Conflicts
Let’s get specific about what we’re dealing with here.
According to incomplete data from Wind (Wande 万得), out of the 42 A-share listed banks, only about 12 have board secretaries without other core management positions.
That means roughly 30 banks—about 71%—are currently in direct violation of the incoming rules.
How the Current Model Actually Works in Chinese Banks
Here’s the breakdown of who’s holding multiple positions right now:
- ~1/3 of the conflicted banks: Deputy Governors serving as Board Secretary
- The rest: Chief Financial Officers, Chief Risk Officers, or Assistants to the Governor also handling board secretary duties
This isn’t a bug in the system—it’s been the intentional design. Banking insiders explain that the “Deputy Governor as Board Secretary” model has become a deeply embedded dependency path within Chinese banking.
One official from a major joint-stock bank explained the rationale:
“The role requires extremely high specialization. You need compliance expertise combined with deep knowledge of asset-liability management, risk management, and credit operations. You can’t just hire a random compliance person off the street and expect them to understand the complexity.”
Major Banks Currently in the Cross-Hairs
The state-owned banking giants are particularly exposed:
- China Construction Bank (Jianshe Yinhang 建设银行): Deputy Governor Ji Zhihong (纪志宏) has been serving as Board Secretary since April 18, 2025
- Bank of China (Zhongguo Yinhang 中国银行): Deputy Governor Liu Chenggang (刘承钢) has been Board Secretary since December 2025
- Postal Savings Bank of China (Youchu Yinhang 邮储银行): Deputy Governor Du Chunye (杜春野) serves as both Board Secretary and Joint Company Secretary
Joint-stock banks are in the same boat:
- China Merchants Bank (Zhaoshang Yinhang 招商银行): Deputy Governor Peng Jiawen (彭家文) serves as both Board Secretary and financial head
- Huaxia Bank (Huaxia Yinhang 华夏银行): Deputy Governor Yang Wei (杨伟) simultaneously holds both roles
What Industry Experts Say About This Shift
Zeng Gang (曾刚), Director of the Shanghai Institution for Finance & Development (Shanghai Jinrong Yu Fazhan Shiyanshi 上海金融与发展实验室), offered his analysis shortly after the rules were released.
His take? This is exactly what the capital markets needed.
According to Zeng Gang:
“The core clauses address long-standing governance pain points in the capital market, particularly within listed financial institutions. These rules will fundamentally break interest bundling and ensure that board secretaries independently carry out information disclosure, governance supervision, and investment/financing compliance control.”
Translation: Separation of duties actually matters, and the CSRC finally decided to enforce it.
But Zeng Gang also acknowledged the realistic timeline:
- Short-term: Listed banks will face “periodic pressure” with organizational adjustments and talent development challenges
- Long-term: This creates a more solid foundation for high-quality development in the financial industry
Other industry insiders pointed out an additional complexity: dual regulatory oversight.
Banks now need approval from both:
- The China Securities Regulatory Commission (CSRC) for board secretary appointments
- The National Financial Regulatory Administration (Guojia Jinrong Jiandu Guanli Zongju 国家金融监督管理总局) and its dispatched offices for banking sector roles
This creates increased transition costs because everything needs dual sign-off.
The Practical Challenge: Finding Qualified Board Secretaries
Here’s where reality gets tricky.
Staffing these new separate board secretary roles requires finding people with a very specific skill set:
- Deep knowledge of banking operations and regulations
- Strong compliance and legal expertise
- Experience with complex financial instruments and risk management
- Understanding of capital market disclosure requirements
For larger state-owned banks, this is manageable—they have internal bench strength and can recruit externally.
But for smaller regional banks? This is a genuine bottleneck.
Analysts expect banks will likely pursue one of two strategies:
- Internal promotions: Move middle management with legal or compliance backgrounds into board secretary roles
- External recruitment: Hire specialized talent from outside the organization
The trick is doing this without disrupting day-to-day operations or losing institutional knowledge.
Timeline: When This Actually Needs to Happen
Here’s the good news: banks aren’t being forced into overnight changes.
The rules take effect May 24, 2026, but the CSRC has provided a transition period extending through the end of 2027.
That gives financial institutions approximately 18+ months to:
- Restructure their executive divisions
- Hire or promote new board secretaries
- Rebuild organizational processes
- Cultivate professional board secretary talent pipelines
According to Zeng Gang, this buffer is deliberate and necessary:
“The transition period provides sufficient space for listed financial institutions to optimize their post-configurations and cultivate professional board secretary talent, ultimately improving information disclosure quality and capital market credibility.”
Standard industry adjustments in other sectors typically take 1-2 months.
But banking is different—qualification approvals can take 3+ months just because of the regulatory approval layers involved.
Why This Matters for Investors and Market Participants
At face value, this seems like internal bureaucratic reshuffling.
But it’s actually a governance quality signal.
When board secretaries operate independently from day-to-day management, they can:
- Provide more objective oversight
- Ensure more transparent information disclosure
- Better control governance and investment/financing compliance risks
- Reduce conflicts of interest in decision-making
This translates to better capital market credibility and potentially more reliable financial reporting from Chinese banks.
It also shows the CSRC is willing to take structural governance seriously, even when it means forcing major institutional changes.
The Bottom Line
China’s new board secretary supervision rules are about to force a governance overhaul across the country’s banking sector.
Nearly 70% of A-share listed banks currently violate the incoming rules by having board secretaries hold concurrent executive positions.
While the transition period through end-of-2027 provides buffer time, banks will need to:
- Navigate dual regulatory approval processes (CSRC + financial regulators)
- Find or develop qualified standalone board secretary talent
- Restructure internal governance frameworks
- Manage short-term organizational disruption
But the long-term payoff could be meaningful: more independent governance oversight, clearer separation of duties, and improved information disclosure quality across the industry.
For investors and stakeholders tracking Chinese financial institutions, this is worth monitoring closely as we move through 2026-2027.
The board secretary supervision rules are now officially in effect—and Chinese banks have 18 months to adapt.
