In recent years, driven by regulatory guidance and industry-wide efforts, the life insurance sector has accelerated its transition towards participating insurance products, achieving phased results. As the industry enters the peak sales period for 2026, new premium income from participating policies already exceeds 70%, making them the dominant product in the market.

From an industry perspective, this shift is understandable. With interest rates trending downward, the operational pressures from traditional high fixed-income liabilities are becoming increasingly apparent. Participating policies, as典型的浮动收益型产品, align with regulatory direction and have a historical operational foundation, naturally positioning them as a key tool to address the new environment.

However, as participating policies move from being a "direction" to a "mainstream" offering, many small and medium-sized insurers are realizing the transition is more complex than initially anticipated. Particularly for companies with relatively weaker operational foundations, investment capabilities, account management skills, and brand recognition, participating policies are not a straightforward solution.

Superficially, the industry is shifting in the same direction, but the specific opportunities, pressures, and constraints brought by participating policies vary significantly across different companies. Against this backdrop, it is necessary for small and medium-sized life insurers to conduct a calmer reassessment of this transition. Currently, at least five major困惑 have emerged regarding participating policies.

The first困惑 questions whether the current participating policies align with the industry's original expectations. Regulatory encouragement of浮动收益型产品 primarily aims to enhance the liability side's adaptability to declining interest rates and market volatility through浮动收益机制, thereby reducing reliance on fixed interest spreads and mitigating interest spread losses. Ideally, the transition should have promoted participating policies with strong收益调节能力, closer to a "low guarantee, high浮动" product structure. However, the reality is that most participating policies in the market exhibit a "high guarantee, low浮动" characteristic. To maintain competitiveness, nearly all insurers design guaranteed benefits near the regulatory上限 of 1.75%. With the演示利率上限 at 3.9%, the potential浮动收益空间 is limited to approximately 1.505%. If the演示利率上限 is further reduced to 3.5%, this space could shrink below 1.225%. This issue is more pronounced for small and medium-sized insurers, as their weaker investment capabilities often result in five-year average investment returns struggling to exceed the regulatory演示利率上限. Consequently, their演示利率 is constrained by actual investment performance, leading to浮动收益率不仅低于行业平均水平 but potentially significantly below 1.2%. In contrast, some Hong Kong participating products offer around 4%浮动收益空间. The narrow浮动收益空间 weakens the essential "regulator" function of participating policies, raising doubts about their effectiveness in hedging operational volatility during periods of declining interest rates. Furthermore, under new accounting standards, participating policies can enhance profit and net asset stability through mechanisms like mirror accounting and Contractual Service Margin (CSM) absorption of volatility. However, "high guarantee, low浮动" products inherently have thinner CSM, making the "safety cushion" vulnerable during significant market fluctuations, thereby diminishing the systemic advantages in asset-liability matching and financial smoothing.

The second困惑 addresses whether small and medium-sized insurers truly possess the capability to manage participating policies. Initially, many were optimistic, assuming that past sales experience and operational methods would suffice. However, market changes over the past two years have revealed that today's participating policies represent a different business model. Firstly, these policies are not as easy to sell as anticipated. Previously, sales were driven by higher演示利率 and supported investment returns, with customers focused on "how high the returns are." In that environment, agent push, bank recommendations, and channel incentives were sufficient. Now, with lower interest rates, increased market volatility, divergent investment performances, and stricter regulatory constraints on演示利率 and dividend levels, customer decision-making has shifted. Customers now compare insurers based on historical dividend fulfillment rates, comprehensive investment returns, brand strength, operational stability, and industry reputation. This comparative mechanism favors larger insurers and those with long-term experience, raising the competitive bar for smaller players. Secondly, participating policies are no longer just a "front-end sell, back-end manage" operation. Previously, sales and operations were often separate; front-end focused on selling, while investment and account management were considered middle and back-office responsibilities, with an assumption that investment returns would cover liability costs. Today, relying solely on investment returns is increasingly unrealistic. Maintaining dividend levels requires coordinated efforts across sales, investment, account management, and asset-liability matching, shifting the operational logic from单纯利差驱动 to a more complex "三差平衡." This demands higher capabilities from insurers, making participating policies a test of systemic operational能力, including sales force, investment prowess, account management,精细化运营能力, and cross-departmental efficiency. The "落差感" among small and medium-sized insurers is understandable. Previously, some managed participating policies by relying on high sales expenses and incentives, coupled with higher investment returns covering liability costs. However, with enhanced regulation on费用和定价利率 and declining market investment returns, these supports have weakened. Competition now revolves around the product itself, investment performance, and comprehensive operational能力—areas where many small and medium-sized insurers are weakest. Thus, the challenge is no longer "whether to sell participating policies" but "whether they have the capability to truly manage them."

The third困惑 questions whether the transition to participating policies is a阶段性策略 or a长期战略. By nature, participating policies are long-term products, with design features like longer break-even periods, coverage terms, and interest rate smoothing mechanisms suited for a长期经营框架. The经营价值 for insurers is not realized short-term. Building customer口碑, market recognition, and historical dividend fulfillment rates requires time. Similarly, developing robust investment capabilities,精细化账户管理能力, and efficient资负联动机制 cannot be achieved quickly. Therefore, participating policies are not a business that can succeed through mere "transition slogans" but require long-term investment, continuous operation, and strategic commitment. However, many small and medium-sized insurers are推动分红险 without sufficient长期规划, often被动跟进 due to regulatory pressure, industry惯性, or应对眼前压力. Many have not clearly considered whether they will长期经营分红险, for how long, or what capabilities will support it. This raises a practical issue: if participating policies are merely a tactical response to阶段性压力 rather than a genuine长期战略, will management and shareholders remain patient if sales pressure mounts, profits thin, and value释放慢? If uncertain, the transition may remain at a "短期跟随" level, failing to develop into sustainable长期能力. For participating policies, the greatest risk is not a slow start but strategic inconsistency, as lack of continuity can undermine accumulated account management, customer trust, and operational investments. Thus, the critical question for small and medium-sized insurers is not "whether to transition" but "whether they are willing to treat participating policies as a长期战略."

The fourth困惑 examines whether the costs and benefits of全面押注分红险 are truly aligned for small and medium-sized insurers. While participating policies are rational for mitigating利差损 and adapting to low-interest environments,全面押注 may not be cost-effective for them. Firstly, small and medium-sized insurers struggle to establish competitive advantages in the participating policy market. Compared to leading insurers, they often have shorter operational histories, lacking long-term experience and historical data. Customers increasingly value historical dividend fulfillment rates, brand, investment capability, and stability—areas where larger insurers excel. Facing larger insurers' decade-long dividend track records and systemic advantages in brand, scale, investment, and management, small and medium-sized insurers start from a弱势地位. Moreover, regulatory constraints on dividend levels mean many small and medium-sized insurers, limited by historical investment returns, account operational年限, special reserve levels, and regulatory ratings, often cannot exceed a 3.2%实际分红水平. To maintain a 100% dividend fulfillment rate, their演示利率 is typically capped near this level, whereas leading insurers can offer around 3.9%, creating a significant product吸引力差距. Secondly, from a经营角度看, the现实贡献 of participating policies to small and medium-sized insurers may be less than expected. Compared to traditional life products, participating policies often have lower价值率, slower利润释放, and longer盈利周期. For insurers already under profit pressure, this means extended waiting periods and limited profit contribution. Additionally, participating policies' future surplus is relatively smaller, resulting in lower偿付能力的贡献效率 compared to ordinary life products. Given that many small and medium-sized insurers already face tight偿付能力 and strong资本约束,全面押注分红险 may not align with their operational reality. Ultimately, participating policies are not without costs; they are chosen not for being perfect but for appearing more suitable in the current environment amid multiple objectives. For resource-constrained, capability-weak small and medium-sized insurers, the decision should not solely follow industry direction but evaluate whether自身投入与回报匹配.

The fifth困惑 asks whether利差损风险 truly decreases after transitioning to participating policies. A core logic of this transition is that the浮动收益机制 reduces reliance on fixed interest spreads, thereby缓释利差损风险. Theoretically, if insurers successfully shift主要业务 to participating policies and effectively utilize the浮动收益调节作用, overall industry利差风险 could decline. However, for many small and medium-sized insurers, reality may differ. Firstly, most current participating policies remain "high guarantee, low浮动" products. Guaranteed benefits are designed near the 1.75% regulatory上限, while演示利率 and actual分配利率 are constrained, leaving limited灵活调节空间. Thus, although nominally浮动收益型产品, their elasticity against market interest rate changes is minimal. Theoretically, insurers could lower guaranteed benefits to gain more调节空间, but for small and medium-sized insurers already disadvantaged, this would further weaken sales competitiveness, making it a difficult step. Secondly,浮动收益 often becomes "刚性化" in practice. While dividends are not guaranteed, many small and medium-sized insurers, to avoid impacting future sales, strive to maintain dividend fulfillment rates, effectively treating浮动收益 as near-guaranteed. This may lead to透支特别储备 to sustain dividends, imposing pressures beyond intended. If浮动收益 remains刚性化, participating policies transform from flexible liability cost regulators into higher-cost, more-constrained fixed-income products. Consequently, instead of reducing利差依赖,负债成本 may not decrease and could even rise due to "保底+隐性刚兑" pressures. Therefore, for many small and medium-sized insurers, participating policies may not inherently lower利差损风险. If产品弹性不足 and浮动机制 is not effectively implemented, they might fail to缓释利差风险 and instead amplify operational pressures under new constraints.

Reflection one suggests that participating policies may not suit all small and medium-sized insurers. As issues emerge, insurers need to reconsider a fundamental question: are participating policies suitable for every company? Operationally, participating policies demand at least three conditions: shareholders and management must have rational expectations for盈利周期, allowing a long战略包容期 for长期价值 cultivation; management must have clear, firm长期规划, not treating them as阶段性策略工具; and the company should possess certain investment能力基础, participating policy经营经验, and strong资负联动能力 to adapt quickly and build competitiveness. However, not all small and medium-sized insurers meet these conditions. Some have shareholders with急盈利要求 and limited战略包容度; some management adopts a "先跟上再说" approach without long-term commitment; others lack necessary foundations in investment, account management, brand, or sales force. In such cases, treating participating policies as the sole focus or全面押注 could amplify existing weaknesses rather than facilitate a smooth transition. Thus, while participating policies can be a转型方向, they are not a universally applicable standard answer. For many insurers, the key is not judging "whether participating policies are the industry direction" but "whether they suit the company itself." This is not merely an operational choice but strategic匹配; a correct direction does not mean equal suitability for all players. Truly rational转型 for small and medium-sized insurers should begin with a清醒认识 of自身能力边界 and资源约束.

Reflection two proposes that转型方向 for small and medium-sized insurers should not be limited to participating policies alone. The rapid industry consensus on participating policies stems from利率持续下行, market volatility, and rising pressures from高固定收益负债, necessitating products better suited to the new environment. Participating policies, with their浮动收益属性 and advantages under new accounting standards for资负匹配, naturally became a优先选择方向. However, the industry's ultimate goal is not "doing participating policies" per se but reducing利率敏感性, mitigating利差损, and enhancing liability-side adaptability. Viewed this way, participating policies should not be the only answer but one of several转型路径. From the perspective of lowering利率敏感性, other浮动收益型产品 like万能险 and投连险 are viable options. Pure risk protection products such as长期医疗险,定期寿险, and定额终身寿险 also help弱化利率敏感性. For防范利差损, promoting low定价利率 products is another feasible path. After multiple预定利率下调, fixed-income products now have a 2.0%预定利率. With further interest rate declines relatively limited, the经营压力 for low定价利率 liabilities has eased significantly. For small and medium-sized insurers weak in participating policy foundations, sales experience, and investment capabilities, pushing low定价利率固定收益产品 sales may be a more pragmatic and realistic choice. Therefore, what small and medium-sized insurers truly need is not simply deciding "whether to follow participating policies" but returning to the转型目标 itself: determining what product structure best suits their股东预期,能力基础,资本约束, and市场定位, and what path can genuinely aid long-term稳健经营 in the new interest rate environment. In this sense, participating policies are not undoable but should not be the only option. For small and medium-sized insurers, what matters may not be following the hottest industry trend but finding the most suitable转型路径 for themselves.