Key takeaway
What This Development Means
China has launched a 2026 programme to strengthen work-safety liability insurance and insurer-funded accident-prevention services in mining, hazardous chemicals, fireworks and metal smelting. Existing law supplies the insurance duty, while the AQ 9010 standards take effect on 1 January 2027.
Does The September Notice Create A New Insurance Duty?
No. The notice implements and intensifies existing requirements under China's Work Safety Law and the insurance measures. The change is the coordinated 2026 programme, regulator registers, inspections and accident-prevention focus, rather than a newly enacted universal obligation.
Are The AQ 9010-2026 Standards Already In Force?
No. The Ministry approved and published AQ 9010.1 to AQ 9010.5-2026 in June, but the official standards notice sets 1 January 2027 as their implementation date. The separate 2026 insurance programme is already active.
Source basis: China Ministry of Emergency Management, notice 应急厅函〔2026〕352号 (29 September 2026)
China Work-Safety Liability Insurance Programme Targets 2026 Coverage
China has launched a national programme to strengthen work-safety liability insurance and insurer-funded accident-prevention services in high-risk industries. Notice 应急厅函〔2026〕352号, issued on 29 September 2026, comes jointly from the Ministry of Emergency Management, the National Financial Regulatory Administration and the National Mine Safety Administration.
The programme covers mining, including oil and gas extraction, hazardous chemicals, fireworks and metal smelting. Regulators must establish or update enterprise registers, share information with insurers and inspect whether covered enterprises have insured all relevant personnel at an adequate level. The programme targets 100% coverage of supervised high-risk enterprises by the end of 2026.
The notice does not create the underlying insurance duty. That duty already comes from China's Work Safety Law and the implementation measures for work-safety liability insurance. Enterprises that are required to insure but have not done so, have omitted personnel or have insufficient cover may face rectification and penalties under the existing legal framework.
Accident Prevention Is Central To Insurer Performance
The notice requires insurers to increase resources for accident-prevention services. Expected activities include legal and mandatory-standard training, compliance self-check support, identification and remediation of major hazards, and safety-standardisation training. The hazardous-chemicals element is particularly relevant to manufacturers, storage operators and service contractors working with major hazard sources.
Insurance does not transfer the employer's primary responsibility for occupational health and safety. Enterprises must continue to identify and control hazards, train workers, maintain equipment, manage contractors and comply with permits, local measures and sector rules. Procurement teams should not treat an insurance certificate as evidence that operational controls are adequate.
The regulators also refer to the AQ 9010 series for accident-prevention services. The official standards announcement confirms that AQ 9010.1 to AQ 9010.5-2026 were issued in June but formally take effect on 1 January 2027. Businesses should distinguish the live 2026 enforcement programme from the standards' later application date.
Registers Will Expose Gaps Across Employers And Insurers
Manufacturers and operators should reconcile legal-entity, site, workforce and contractor data against policies and regulator registers. Insurers should document how prevention budgets, service-provider competence, findings and follow-up actions address the sector-specific risks described in AQ 9010.
Shared registers can make mismatches visible across several authorities. Incomplete personnel coverage, stale site details or weak prevention records may therefore create both insurance and work-safety scrutiny, even without an accident.
The programme follows other recent changes to China's safety framework, including mandatory personal protective equipment standards and the GB/T 47911-2026 management standard for small enterprises. Each instrument has a different legal status, scope and start date.
Summary
Businesses should confirm whether each Chinese site falls within a covered high-risk sector and check that every relevant worker is insured. They should also prepare a documented transition to the applicable AQ 9010 standard before 1 January 2027.
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