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  • Partner Zhao Zhanling was interviewed by Sohu Finance, analysing the legal issues surrounding claims arising from online stock trading courses

    Release Time:2026-03-27

    As the ‘Generation Z’ and ‘Millennial’ generations—digital natives of the mobile internet—become the driving force behind new account openings in the A-share market, they are bringing their information-gathering habits, honed on social media platforms, into the capital markets—scrolling through Xiaohongshu and Douyin to learn how to pick stocks, copying strategies from financial bloggers, and even turning wealth management topics into social currency. However, as screenshots of high-return trades intertwine with ‘expert personas’ to become the secret to generating traffic, and as paid stock-recommendation groups and WeChat private domains teem with undercurrents, this ‘mutual pursuit’ between young people and the capital market is evolving into a profound contest concerning regulatory boundaries, investment risks and platform accountability.

     

    In light of this, Mr Zhao Zhanling, a partner at JAVY Law Firm, spoke to Sohu Finance to provide an in-depth analysis of the issues at hand.

     

    01 Young People Learning to Trade

     

    Xiaoping, a girl born in the 2000s, began her journey into the stock market at the start of this year. Her stock-picking logic involves first browsing content from bloggers and algorithm-driven recommendations on social media; if something catches her interest, she delves into the comments section before researching news and studying candlestick charts herself. Xiaoping is a microcosm of the vast army of young investors. At the same time, a wave of financial bloggers has emerged on social media in recent years. Using ‘live trading screenshots’ and ‘investment experience sharing’ promising high returns as their selling points, they have rapidly gathered a following, even prompting large numbers of fans to ‘copy their homework’ and follow their investment strategies.

     

    Towards the end of last year, influenced by several bloggers, Xiaoping invested 10,000 yuan in non-ferrous metal-related funds and shares. Since March, the market has underperformed and she has yet to make a profit, but seeing that the bloggers remain optimistic, she firmly believes that “it will bounce back sooner or later”. Of course, Xiaoping considered herself a discerning investor, not the sort who “buys whatever others tell her to”. In addition to the bloggers’ recommendations, she would combine her own understanding of the stock with her accumulated financial knowledge. She believed that investing was an essential skill, and that stock trading was a good way to manage idle funds; indeed, this approach to investing was becoming the choice of an increasing number of young people.

     

    Data released by the Shanghai Stock Exchange in January 2026 showed that the cumulative number of new A-share accounts opened in 2025 reached 27.4369 million, a year-on-year increase of 9.75%, marking a three-year high. Further data indicated that those under 35—the ‘post-90s’ and ‘post-00s’ generations—have become the dominant force driving this growth, accounting for over 45% of new accounts.

     

    As a generation that has grown up alongside the mobile internet, these young people’s development has been deeply intertwined with content communities such as Bilibili, Xiaohongshu and Douyin. They are accustomed to using social media platforms to gather information—from fashion tutorials to travel guides, and from tips on avoiding pitfalls when renting to advice on postgraduate entrance exams. Now, they have extended this approach to the capital markets.

     

    02 The Business Behind the Traffic

     

    As vast numbers of young people flood into the stock market, financial content on social media platforms is also experiencing explosive growth. The ‘Xiaohongshu Financial Industry White Paper’ reveals that in 2025, categories related to finance, wealth management and general financial topics on Xiaohongshu grew rapidly. Specifically, the number of views for ‘financial planning’ posts increased by 104% year-on-year, whilst the average daily number of active posts rose by 107%.

    Take live-trading bloggers as an example: the most classic tactic for driving traffic is to document a ‘small-capital doubling challenge’. Once followers are lured by the high returns showcased and gather in the platform’s fan groups, the influencer then shifts traffic to their private WeChat domain under the pretext of “copying strategies” or “preventing loss of contact”.

     

    The same scenario is playing out on other platforms, even raising deeper industry compliance issues.

     

    In January 2026, a regulatory notice disclosed by the China Securities Regulatory Commission (CSRC) sparked heated debate. The notice stated that Fund Company D had entered into marketing partnerships with internet ‘influencers’ who lacked the necessary qualifications for fund sales or fund industry practice. The company paid these influencers substantial advertising fees, using the influencers’ announcements on their platforms—promising to make large-scale purchases of Fund Company D’s Product A on a specific date—as a marketing gimmick. By leveraging the influencers’ traffic and influence, the company encouraged investors to follow suit and purchase Product A.

     

    A more covert method involved exploiting their fame to profit from reverse trading of individual stocks. In January 2026, a case published by the Zhejiang Securities Regulatory Bureau revealed that Jin Yongrong had long used the account “Jin Hong” to post stock recommendations on the Snowball platform. By participating in live trading competitions and sharing stock-picking logic via live streams, he built up a reputation and audience, amassing over 100,000 followers. He subsequently profited by engaging in reverse trading of individual stocks, ultimately facing a total penalty and confiscation of over 83 million yuan, as well as a three-year ban from the securities market.

     

    03 The ‘Cat-and-Mouse Game’ on the Platform

     

    These bloggers and the platform are engaged in a tacit ‘cat-and-mouse game’. Virtually every blogger with even a modest following will label a secondary account on their profile as a ‘backup account’ in case of emergencies. When posting screenshots of live trading, some bloggers will deliberately blur key words in the stock names, yet retain enough information for followers to ‘get the gist’. Almost every post concludes with a disclaimer stating “Invest with caution” or “This does not constitute investment advice”. Although the Xiaohongshu Community Guidelines explicitly prohibit unqualified advice in professional fields such as healthcare and investment, violations remain rampant.

     

    In the view of lawyer Zhao Zhanling, the key distinction between “genuine sharing” and “illegal stock recommendations” lies in the intent behind the action and the targeted nature of the information exchange.

     

    “Normal sharing” typically involves bloggers expressing personal views based on publicly available information or documenting their own investment journeys; this falls within the scope of freedom of speech, with the aim of fostering discussion rather than directly guiding specific followers to trade. In contrast, the core characteristic of “illegal stock recommendations” is that they constitute securities investment advisory activities.

     

    Lawyer Zhao Zhanling points out that there are three main criteria for determining “illegal stock recommendations”:

     

    Firstly, proactivity: whether specific securities are recommended for buying or selling; secondly, financial interest: whether economic benefits are obtained through fees, tips, or traffic redirection; and thirdly, authority and trust: whether an expert persona is cultivated to instil trust in followers, thereby influencing their independent decision-making.

    “Any act of providing securities investment advice to the general public for profit without the approval of the China Securities Regulatory Commission, regardless of how covert the form, is suspected of constituting illegal stock recommendation.”

     

    When young investors who have followed recommendations suffer losses, who should bear the cost?

     

    Lawyer Zhao Zhanling stated that when followers seek redress from bloggers for losses incurred by following their investment recommendations, this constitutes a civil dispute in legal terms, with the crux of the matter being whether the blogger’s negligence can be proven. If the blogger merely shares opinions without promising returns or charging fees, it is generally difficult to hold them legally liable, as investment inherently carries risks. However, if the blogger makes binding statements (such as “guaranteed returns”), or if there is a paid service relationship, or if the blogger makes false statements or uses misleading language, compensation may be sought on the grounds of fraud or illegal business operations.

     

    He also admitted, however, that in reality, the success rate of individual claims is relatively low, primarily due to the difficulty of gathering evidence, and because many bloggers disclaim liability by stating that their content “represents personal views only and does not constitute investment advice”.

     

    As for the scope of a platform’s liability, the ‘notice-and-takedown’ safe harbour principle generally applies. Lawyer Zhao Zhanling stated that platforms can avoid liability by promptly removing content upon receiving a notice of infringement from a user. However, the situation differs when algorithmic recommendations are involved.

     

    Lawyer Zhao Zhanling indicated that the circumstances in which platforms are held liable primarily include:

     

    Firstly, where algorithms have substantially recommended illegal content; that is, where the platform uses algorithms to push clearly non-compliant stock recommendation content to users, which may constitute contributory infringement; secondly, where the platform has failed to fulfil its duty of review, knowing or having reason to know that a blogger has been engaged in illegal stock recommendation activities for a long period yet failing to take restrictive measures; thirdly, where the platform is directly involved in profit-sharing, such as collaborating with bloggers to obtain a share of revenue from paid stock recommendations.


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