国家金融监督管理总局就《保险公司董事、监事和高级管理人员任职资格管理办法（征求意见稿）》公开征求意见

The draft sets out a six-chapter, 66-article framework covering regulatory division of responsibilities, role scope, fit-and-proper criteria, approval and reporting procedures, post-appointment supervision and legal consequences. For compliance and governance teams, the practical effect is a more prescriptive approach to leadership appointments: candidates will need to evidence integrity, diligence, clean conduct, relevant financial-sector experience and position-specific qualifications, while firms must manage expanded documentation, approval/reporting and ongoing supervision obligations. The draft also signals sharper consequences for unsuitable appointments, including refusal, revocation and industry bans, and addresses acting arrangements and same-level transfers.

Compliance teams should assess which roles fall within scope, refresh due-diligence and nomination files, update board/committee appointment procedures, and prepare for more granular regulator interaction. Insurers should also monitor the consultation and final text for changes to reporting thresholds and material requirements. Risks include approval delays, leadership succession disruption and enforcement exposure; opportunities include stronger governance, clearer appointment workflows and competitive advantage from demonstrably robust fit-and-proper controls.

Small and mid-sized insurers may face proportionately higher implementation burden, while larger groups should align group and subsidiary appointment processes.