Fiduciary Services Accelerate Market Entry; Prepaid Consumption "Anti-Evasion" Reveals New Measures

Pet stores that go bankrupt immediately after recharging, training institutions that go offline two weeks after classes begin, prepaid deposits for new energy vehicle charging stations that are not refunded for a long time… Confronted with these frustrating issues that almost everyone encounters in prepaid consumption, a new solution path has emerged.

In early 2026, 67 families with young children in Liaocheng, Shandong, quickly received refunds after their kindergarten ceased operations, making the advantages of the service trust model in addressing prepaid fund safety issues tangible. In recent years, trust companies such as Bank of Communications Guoxin, Shandong Guoxin, Bohai Trust, and Guomin Trust have been actively developing prepaid fund service trusts, covering areas from education and training to elderly care, from ETC to community services. The trust system is embedding itself into various consumption scenarios as a protector of funds, installing safety valves in the prepaid consumption market.

Targeting the pain points of prepaid consumption

Currently, prepaid consumption has become a new mainstream consumption pattern in the life service sector. However, the reality is that “disappearing bosses” frequently appear, with prepaid cards turning into “money swallowing cards,” and hidden financial risks difficult to eliminate. A search on the Heimao Complaint Platform using the keyword “prepaid” revealed over 20,000 complaints, mostly about refusing to refund unused services, store closures, and refund refusals.

“After the elderly make payments, some companies can move the money away in the morning and afternoon. This is not new,” said Qian Yuliang, General Manager of Bohai Trust’s Wealth Business Department. Seeing this pain point, Bohai Trust began exploring in the elderly care service scene.

Based on customer demands and industry pain points, Bohai Trust creatively proposed a养老消费信托账户 (elderly care consumption trust account) solution, starting with陪诊业务 (companionship diagnosis services). The scheme involves护仁养老 (Huren Elderly Care) as the entrustor and Bohai Trust as the trustee, establishing the “Bohai Trust·2025 Silver Age Guardianship No.1 Service Trust.” Elderly people deposit their陪诊服务费 (companionship diagnosis service fee) into the elderly care trust account, which is supervised by Bohai Trust. After the service is completed, the consumption is confirmed, achieving fund risk isolation and ensuring the safety of elderly people’s funds used for elderly care services.

“Previously, the elderly paid directly to the enterprise, but now they pay into a trust account. The money is not nominally owned by the enterprise but held in an independent account under the trust company’s name, with the enterprise only managing it and not able to misuse it,” explained Qian Yuliang.

The new trust business regulations implemented in 2023 divide trust businesses into three categories: asset service trusts, asset management trusts, and public welfare charitable trusts. Prepaid fund service trusts fall under the asset service trust category, which includes administrative management services such as trust property custody, rights registration, payment and settlement, enforcement supervision, information disclosure, and liquidation and distribution.

Currently, more and more trust companies are entering this field. Suzhou Trust established the Suzhou Prepaid Consumption Fund Management Platform; Bank of Communications Guoxin launched a prepaid ETC fund service trust; Shanghai Trust, supported by the Huangpu District Sports Bureau, successfully put into operation the first batch of fitness venues using the service trust model; Kunlun Trust launched the “Fangxin Chong” service platform; Guomin Trust successfully incubated prepaid fund supervision platforms such as Jinan Prepaid Treasure, Alipay Safe Pay, and Liaocheng “Liao An Pay”… These practices cover scenarios like education and training, community consumption, and transportation.

According to the “China Trust Industry Fintech Application Development Report (2024)” released by the Trust Industry Association at the end of 2025, compared to 2023, the number of trust companies conducting prepaid fund service trusts increased by 6, reaching a total of 30, with 14 trust companies building service platforms for prepaid fund trusts.

Why trust is a “safety cushion” for funds

Currently, prepaid fund supervision mainly includes three models: bank custody, insurance guarantees, and service trusts.

“The trust system has unique advantages such as asset independence, risk isolation, and rights restructuring, which can effectively safeguard prepaid funds, and can be combined with financial tools like bank custody and insurance guarantees to balance the interests of all parties,” said a relevant business person from a trust company in eastern China. This advantage has been validated in practice in Liaocheng, Shandong. In early 2026, after a kindergarten in Liaocheng ceased operations, the “Liao An Pay” platform quickly activated an emergency plan—Guomin Trust, as the trustee, used its professional fund accounting capabilities to verify each of the 67 families’ recharge, consumption, and balance records, and quickly completed precise refunds of unspent funds.

“Relying on the independence of the trust system to fully isolate consumer prepaid funds from merchants’ own funds, thoroughly protecting consumer prepaid funds,” said Zhao Zhishan, head of the prepaid funds business department at Guomin Trust.

The same applies in elderly care scenarios. In December 2025, Shandong Guoxin launched the first prepaid fund service trust in Shandong Province focused on elderly care, the Shandong Trust - Trust Elderly Care Prepaid Fund Service Trust. Zaozhuang Yishun Elderly Care, as the project entrustor and elderly care service provider, deposits pre-collected bed fees, service fees, and other funds as trust property, managed through a dedicated trust account. Shandong Guoxin, as the trustee, performs account management, payment review, and enforcement supervision.

“Through a dual supervision structure of ‘trustee + custody,’ the operating funds of elderly care institutions are separated from consumers’ prepaid funds, and independent external supervision effectively prevents fund misappropriation, ensuring the property safety of elderly consumers,” said a relevant staff member from Shandong Guoxin.

In operational terms, a manager from a large trust company’s service trust department explained that under the service trust model, the trust company mainly opens and manages the trust account, receives and safeguards prepaid funds, disburses funds to merchants according to the trust contract, and supervises merchant operations. As consumers use their membership benefits, the trust company releases corresponding prepaid funds to merchants. If the merchant defaults, the trust company can take measures according to the trust contract to protect consumers’ legal rights.

From single-point breakthroughs to multi-party collaboration

Despite the clear advantages of the system, promoting prepaid fund service trusts still faces practical challenges. “Using a single function to negotiate prepaid fund supervision with enterprises, they will inevitably feel burdened,” admitted Qian Yuliang. Trust companies need to offer comprehensive value to persuade merchants.

Bohai Trust’s approach is to deploy a combination of strategies—besides ensuring fund safety, they also provide fund appreciation services, attracting compliant institutions with the yield on deposited funds, and emphasize the separation of business funds from corporate financial funds to help prevent operational risks from spilling over.

Many interviewees believe that relying solely on trust companies’ own efforts is far from enough. A multi-party collaborative governance model involving “government leadership + trust supervision + bank custody + government service platform support” must be built. All parties need to work closely, leverage their strengths, and ensure the safety of prepaid funds.

“Trust companies should not aim solely for management fees but should view them as entry points into livelihood scenarios, ultimately following a development path of ‘volume-based cost exchange and scenario-based value exchange,’” Zhao Zhishan explained. First, they need to connect with government regulatory platforms and gain government support to scale up and reduce costs; second, they should leverage transaction data to provide value-added services like settlement and financing for merchants; third, they can extend into wealth management and inclusive finance, ultimately building industry brands.

This approach is being validated in practice across various regions. In March 2026, Zhengzhou officially launched the “Zheng Prepaid” platform, led by the Zhengzhou Market Supervision Bureau and developed and operated by Zhongyuan Trust, creating a model of “government leadership + trust supervision + bank custody + government service platform support.” Consumers can complete the entire process of card purchase, consumption, and refunds via the “Zhenghao Ban” app, with funds fully separated from merchants’ own assets.

Additionally, the “Trust + Bank + Payment Platform” model of prepaid fund supervision jointly created by Guomin Trust, Alipay, and Industrial and Commercial Bank of China has been officially implemented through projects like Jinan “Prepaid Treasure.” In this model, Guomin Trust acts as the central platform for prepaid fund supervision, providing property custody, rights registration, and enforcement supervision services. “It interfaces with Alipay to receive consumer card purchase, consumption, and refund information, and connects with ICBC’s platform to execute fund transfers by sending instructions,” Zhao Zhishan said. This model offers a one-stop, convenient experience via Alipay, considering merchants’ cash flow and fund needs, and is practical and inclusive. It has been included in the 2025 national standardization pilot project list, laying a foundation for large-scale, standardized promotion.