---
title: INE Tightens Rules on Linked Trading Accounts
description: The Shanghai International Energy Exchange (INE) has updated its rules regarding the administration of accounts involving actual control relationships which has implications for overseas trading firms.
image: https://www.regtrail.com/hubfs/Blog%20Images%2028%20Sep%20%E2%80%93%202%20Oct-1.png
---
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# INE Tightens Rules on Linked Trading Accounts
RegTrail | 30 September, 2026
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**The Shanghai International Energy Exchange (INE) published revised rules regarding the administration of accounts involving actual control relationships (click [here](https://www.ine.cn/eng/circularnews/circular/202609/t20260930_833614.html)). The exchange's rules on *Administration of Accounts Involving Actual Control Relationship* govern how the INE identifies and administers futures accounts where one person controls (or significantly influences) the trading decisions of another. Their main purpose is to stop participants using multiple accounts to get around position limits, intraday open position volume limits and abnormal trading behaviour controls set by the exchange. Intraday open position volume limit breaches are frequently enforced by the INE, as regularly reported by RegTrail.**
The rules apply a "substance over form" approach in making determinations over control. Relevant to this week's announcement is the distinction between Futures Firm Members (FF Members), which are licensed mainland Chinese futures companies that are members of the INE and can trade and clear on behalf of Clients (both domestic and overseas), Overseas Special Brokerage Participants (OSBPs), which are foreign brokers admitted to trade directly on the INE on behalf of overseas Clients, and Overseas Intermediaries, which are foreign brokers that do not trade on the exchange directly but instead route their trading and clearing through an FF Member or an OSBP. By contrast, Non-Futures Firm Members (Non-FF Members) and Overseas Special Non-Brokerage Participants (OSNBPs) are domestic and foreign entities that trade directly on the INE for their own account only. *Clients* are entities that trade on the INE through one of those three entities rather than directly as an exchange participant.
The recent changes to the rules widen who they apply to and strengthen the INE's powers to identify and act against undeclared linked accounts. Article 5 introduces a new subparagraph which deems that actual control exists where two parties show identical trading behaviour and either one funds the other's trading or they share the same trading terminal information. This means that accounts can be treated as linked even without any ownership or management connection. Article 10 extends the INE's inquiry powers over suspected unfiled linked accounts to Non-FF Members and OSNBPs, which it can now question directly. It also allows the INE to inquire into a Client's account directly, rather than only through the Client's FF Member or OSBP. Article 11 extends the inquiry-response process to Non-FF Members and OSNBPs. Anyone denying an actual control relationship must now submit a written explanation and sign a Compliance Statement and Undertaking. Where such explanations are inadequate, the INE will now require the account to be filed as having a control relationship. If this isn't done within the prescribed time, the exchange can unilaterally determine that actual control exists. Where the INE can't reach such a conclusion, it can now place the given party on a watch list, presumably subjecting it to greater compliance scrutiny.
Article 12 now extends the INE's sanctions to Non-FF Members and OSNBPs and sets out four specific triggers, two of which are new, namely failing to file a relationship in order to get around the INE's abnormal trading or risk controls, and providing false materials to have a relationship removed. On the available sanctions, "suspending" the opening of new positions now becomes "limiting" the opening of new positions along with giving a verbal alert or issuing a warning letter. The INE can also now limit fund withdrawals. The reference allowing the INE to take further action under the *Enforcement Rules of the Shanghai International Energy Exchange* (click [here](https://www.ine.cn/eng/services/rules/rulebook/202111/t20211119_821537.html)) for serious cases has been deleted, as this is now covered by a new standalone article (Article 20) which applies to any violation of the control rules (not just the serious ones). The *Compliance Statement and Undertaking* mentioned above has been deleted from the Annex and is now a freestanding form.
The announcement is accompanied by a comparative table of the old and new rules and a clean version of the revised rules (note that where the English and Chinese versions differ, the Chinese version prevails). The new rules take effect on 20 October 2026. Firms active on the INE should consider two points before this date.
First, firms trading as Clients, whether through an OSBP or an Overseas Intermediary, should check whether entities or funds within their group share trading funds or trading terminal information (e.g. a common execution desk or order management system). Under the new Article 5 criterion, such accounts may be treated as linked and aggregated for position limit and intraday open position volume purposes, and will therefore need to be filed with the China Futures Market Monitoring Center (CFMMC) - the body responsible for monitoring futures accounts and margin across China's futures markets.
Second, the INE may now inquire into Client accounts directly, rather than only through their FF Member or OSBP. Where a firm trades through an Overseas Intermediary, inquiries will typically pass through an additional link in the chain, leaving less time to respond. Given the new watch list, deemed determinations of control and limits on fund withdrawals, firms should ensure that both front and back offices can respond promptly and accurately to any such inquiry.
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