by:Mark Schaub, Shawn Hu and Zheng Wei 

A new report by UBS Securities forecasts that China’s online education market will continue to massively grow from the already sizeable RMB 30 billion annual spend in 2018.

Online education marries two of the hottest sectors in China – education and the internet. Although one may not immediately link the two sectors, they do share a lot in common. Both are strongly supported by the PRC authorities but also subject to increased scrutiny. In addition, education and technology closely touch the lives of most Chinese consumers.

Although the initiatives are varied there are some common themes – encouragement for technology playing an expanded role in education; cooperation between PRC authorities; better regulation (i.e. requiring registrations) etc. 

Variety of Measures

There has been a variety of recent initiatives related to how education is envisioned in China:

Internet Plus Education

The Ministry of Education (MOE) has recently updated their website with guidelines highlighting the need to deepen reforms in the higher education space by specifically incorporating “Internet Plus Education” and “smart” education.

On 29 September 2019, the MOE’s updated guidelines aim to revitalize undergraduate education and improve the overall quality of talent cultivation. The guidelines specifically encourage the development of “Internet Plus Education” and exploration of new forms of “smart” education so as to promote a new way to conduct classroom teaching.

These guidelines follow an August 2019 executive meeting of the State Council in which Premier Li Keqiang stated the government will encourage qualified entities to develop their online education offerings and by 2022 put forward an Education Informatization 2.0 Action Plan which would detail preferential policies for online education and also opening up the sector to more opportunities.

The guidelines and other pronouncements have been general in nature and would not be considered to be breaking news but important in that such statements do shed light on how the PRC government seems to be allocating both its attention and perhaps more importantly its spending.

China’s focus on an increased role for technology in Chinese education institutions will give technology companies potential opportunities.

Although, technology will unlock new opportunities it will also result in additional challenges for the technology companies and education institutes as to how they operate. In this regard, companies and education institutes need to pay more attention to issues such as storage of student data, securing data privacy and ensuring staff are up to date on technology related compliance requirements.

Another issue for education institutes in particular is that MOE will likely not be the only rule setter. Accordingly, it is very likely that other government regulatory bodies (such as the Ministry of Industry and Information Technology (MIIT) will also be relevant.

From a practical perspective, Internet Plus Education may ease the imbalance in allocation of education resources by empowering students in remote and less developed areas to have better access to education. On an even more practical level students may be able to dodge China’s traffic jams – which can greatly eat into the already busy students’ time schedules – as much of the internet plus education will be additional study.

Examples of Internet Plus Education in China T University: – first MOOC platform in China

The cooperative online education project between T University and F University through the Chinese MOOC platform ( is an early practical example of Internet Plus Education. T University established the platform in October 2013 and it is the first MOOC platform in China. In May 2015, T PBC School of Finance and F School of Economics launched the first cooperative teaching project in China that combines an online and offline study model for undergraduate students wishing to take finance as a second major. The two academies 1) jointly planned and designed the curriculum and took charge of the teaching tasks of the different courses respectively based on the “school online” platform (; 2) enrolled qualified students and 3) mutually recognized the relevant online courses.

S University: Personalized Homework System

S University’s online “personalized homework system” allows 259 online courses to assign different homework to different students based on big data analysis. The system can record and analyze the online learning habits of students and assign different assignments accordingly. The system will assign more reading tasks for students undertaking a limited amount of extracurricular reading. Students with low accuracy rates will be provided with customized special tests to deal with particular aspects.

Implementation Opinion Regulating After-school Online Training (“Online Training Opinion”)

The MOE together with five other regulators issued the Online Training Opinion on 12 July 2019 which emphasizes the filing requirements for online tutoring at the provincial education authorities, sets out the filing materials required (i.e. ICP filing/license), content of training, etc. The filing requirement is not new and has been in force since 2018.

Opinion on Guiding and Regulating the Development of Educational Mobile Internet Apps (the “Apps Opinion”)

The MOE together with seven other regulators issued the Apps Opinion on 15 August 2019. The definition of “Educational Mobile Internet Apps” under the Apps Opinion is very broad, and covers all mobile applications used by teachers, students and parents in an educational setting, learning scenarios for the purpose of teaching and management, learning, home-school interaction and other education related activities.

The providers of the Educational Mobile Internet Apps are required to make filings with the provincial education authorities after obtaining the ICP filing/license. There are also requirements for the content and use of such Educational Mobile Internet Apps and restrictions on the collection of personal information.


Both technology companies and education institutes face new opportunities in China. However, the opportunities will also result in greater requirements for registration and ensuring compliance, especially with privacy requirements. Furthermore, PRC authorities do recognize that technology and education often intersect and this is reflected by the increased collaboration in such regard.