Core Insights - The article discusses the "Pure Code" parking payment system in Shanghai, which enhances personal information protection while streamlining payment processes [1][3][4] - The "Liangjian Pujiang" initiative aims to improve governance in digital consumption scenarios, focusing on personal information rights protection [2][5][19] Group 1: Governance and Innovation - The "Pure Code" system exemplifies a shift in governance philosophy, transforming abstract legal principles into tangible benefits for citizens [1][4] - The initiative has expanded from basic payment scenarios to more complex areas like facial recognition and AI misuse, showcasing a comprehensive approach to digital governance [1][2][5] Group 2: Implementation and Impact - The "Liangjian Pujiang" initiative has identified eight key consumer scenarios for personal information protection, including parking payments and online education [2][5] - As of November 2023, the initiative has led to significant compliance improvements across various sectors, with over 5,500 establishments undergoing rectification [5][17] Group 3: Future Directions - The initiative is set to address more challenging issues like facial recognition technology misuse, establishing a framework for responsible use [9][12] - By 2025, the focus will shift towards creating a sustainable legal ecosystem that balances development and security, emphasizing proactive governance [13][20]

Core Viewpoint - The article discusses the recent draft of the "Internet Platform Antitrust Compliance Guidelines" aimed at guiding platform operators to prevent antitrust compliance risks and promote fair competition in the platform economy [2][3]. Group 1: Purpose and Importance of the Guidelines - The Compliance Guidelines are designed to support platform operators in establishing effective antitrust compliance management mechanisms and protecting the legitimate rights of relevant parties [2]. - The guidelines reflect the sensitivity and adaptability of domestic antitrust authorities to new market conditions and models, addressing the complexities introduced by the rapid development of the platform economy [2][3]. Group 2: Challenges in Antitrust Compliance - The platform economy faces new antitrust compliance anxieties, including algorithm collusion, abuse of market dominance, and unfair pricing practices, which can infringe on the legitimate rights of others and disrupt fair competition [3][4]. - Identifying and assessing the compliance boundaries of potentially monopolistic behaviors is a key concern for all parties involved in the platform economy [3][4]. Group 3: Cooperative Governance Approach - The Compliance Guidelines represent a beneficial attempt at cooperative governance, signaling that regulators and platform participants share a common goal of seeking fair competition [4][6]. - This approach aims to improve perceptions of regulation as a facilitator of order rather than a mere restriction on participants' freedoms [4][6]. Group 4: Addressing the Rights of Weaker Parties - A significant issue in antitrust activities is the inadequate protection of the legitimate rights of weaker parties, which often face high costs in defending their rights and lack effective channels for legal recourse [5]. - The cooperative governance model seeks to enhance the protection of weaker parties' rights and establish mechanisms for low-cost rights protection and expression [5]. Group 5: Implementation and Communication - The Compliance Guidelines utilize non-coercive directives to foster cooperation between regulators and those being regulated, establishing an effective communication mechanism for governance improvement [6].

2025.11. 16 合规是任何企业持续经营的必要条件。合规在法理上并非单纯地满足相关法律法规的要求，其深层逻 辑是如何防范自身行为有意无意侵犯其他主体的合法权益，同时有效促进竞争合规、规则公平、算法 向善。 当前平台经济在牵涉垄断协议、滥用市场支配地位等垄断行为方面，面临新的反垄断合规焦虑，如平 台间算法共谋、组织帮助平台内经营者达成垄断协议、平台不公平高价、平台低于成本销售、封禁屏 蔽、"二选一"行为、全国最低价和平台差别待遇等。这些可能涉嫌垄断的行为有一个很明显的辨识 点，即这些行为都在不同层面对他人合法权益构成侵害，都有损公平竞争秩序。 如何有效辨识和评估这些行为的合规边界，是参与平台经济的各方都期待明晰的问题。此次《合规指 引》既通过站在监管仲裁者角度，让平台经营者和商家等换位思考其行为可能面临的外部性，让其了 解监管者会如何看待其行为的边际影响，又有助于监管者积极主动了解平台经济引发的新现象、新问 题，提高监管的敏感性，同时也适度在事前事中指引平台运营者和商家的行为，减轻垄断行为的事后 规制压力。 显然，《合规指引》在规制经济学角度看，是一种合作治理的有益尝试，其向各方传递出一个信号， 监管与平 ...

Core Viewpoint - The "Compliance Guidelines" aim to establish an effective communication mechanism between regulators and regulated entities, promoting cooperation in governance and enhancing antitrust compliance management within the platform economy [1][6]. Summary by Sections Regulatory Context - The State Administration for Market Regulation has drafted the "Antitrust Compliance Guidelines for Internet Platforms (Draft for Public Consultation)" to guide platform operators in preventing antitrust compliance risks and protecting legitimate rights and interests [1][2]. Market Dynamics - The rapid development of the platform economy has improved resource allocation efficiency and driven technological innovation, but it has also introduced complexities in antitrust regulation due to the unique characteristics of platform markets, such as bilateral market features and multi-party transaction structures [2][3]. Compliance Challenges - Current antitrust compliance anxieties include issues like algorithm collusion, unfair pricing, and discriminatory treatment among platforms, which can infringe on the legitimate rights of others and disrupt fair competition [3][5]. Cooperative Governance - The guidelines represent a beneficial attempt at cooperative governance, signaling that regulators and platform participants share a common goal of achieving fair competition, thus improving perceptions of regulation as a facilitator rather than a restriction [4][6]. Protection of Vulnerable Parties - A significant issue in antitrust activities is the inadequate protection of the legitimate rights of weaker parties in transactions, necessitating the establishment of low-cost channels for rights protection and the introduction of collective litigation and other mechanisms to balance competitive fairness [5][6].