Introduction
With the steady growth of China's macro-economy and the comprehensive upgrade of people's cultural consumption needs, the performing arts economy has experienced explosive expansion in the past few years, and has rapidly entered a new era of refined, standardized and high-quality development from the early stage of extensive growth. As the core digital hub connecting performance organizers, performing arts venues, consumers and administrative regulatory agencies, the performing arts ticketing platform plays an irreplaceable infrastructure role in the modern cultural market. However, with the rapid expansion of the ticketing market, the platform has also exposed a series of deep-seated structural contradictions in the process of commercialization: the extreme imbalance between ticket supply and demand, the continuous iterative upgrade of "scalper" ticket scalping technology, and the rigid "no refund" rule. Issues such as the collective consumer rights protection crisis, fairness disputes caused by the abuse of ticket distribution algorithms, and value-oriented deviations caused by lax review of performance content have frequently pushed the entertainment ticketing market to the forefront of public opinion and the spotlight of administrative supervision.
Entering 2026, core ministries and commissions such as the Ministry of Culture and Tourism, the Ministry of Public Security, the State Administration for Market Regulation, and the State Internet Information Office have built a three-dimensional and penetrating regulatory matrix around the entertainment ticketing market that spans cultural industry access, Internet information services, network data security, and consumer rights protection. For large-scale commercial performances with high social attention and tight ticket supply and demand, regulators have continuously tightened compliance standards and put forward step-by-step hard constraints on the operating qualifications of ticketing platforms, transparency of ticket circulation, cancellation and change mechanisms, and application of algorithmic technology. This report aims to provide a panoramic and multi-dimensional dismantling of the compliance points faced by performing arts ticketing platforms in daily operations and strategic expansion based on current laws and regulations, national and industry technical standards, and in-depth integration of typical cases of violations reported by comprehensive law enforcement teams at all levels of the cultural market in recent years. Through in-depth analysis of the underlying logic and systematic construction of forward-looking countermeasures, it provides solid theoretical support and practical guidance for the efficient, legal, and stable operation of the ticketing system.
1. Unified regulation of top-level system design and underlying technical standards for ticketing
The compliance system of the performing arts ticketing market does not rely solely on administrative penalties to maintain, but is based on a high degree of unification of underlying technical standards and absolute specifications of data interfaces. For a long period of time, the domestic performance ticketing market has been characterized by fragmentation among princes and isolated systems. The lack of interoperability of data between different ticketing platforms and organizers directly makes it difficult for regulatory authorities to effectively penetrate the true flow of ticket sources, actual ticket sales rates, and overall box office revenue. This also provides a breeding ground for various illegal black-box operations.
In order to fundamentally break down the technical barriers of this industry and consolidate the digital supervision base of the cultural market, the China Performance Industry Association took the lead in drafting the "Performance Ticketing System Service and Technical Specifications" (Cultural Industry Standard WH/T 93-2021), which is regarded as WH/T 78 An important part of the "Performance Safety" series of standards, which was officially released by the Department of Science, Technology and Education of the Ministry of Culture and Tourism on July 19, 2021, and is fully implemented as a mandatory technical guideline for the national performing arts ticketing industry 1. The implementation of this standard marks that China's performing arts ticketing market has officially bid farewell to the disorderly state of "barbaric growth" and entered a new stage of standardization, data-based compliance.
The core value of this technical specification is that it completely unifies the basic principles and specific operating specifications for performance ticketing across the country, and strictly defines the entire life cycle process of ticket purchase, check-in, and refund 2. More importantly, the standard stipulates the technical requirements, functional module design, and server security management standards for the performance ticketing management system and sales system on the underlying architecture, and specifies in detail the communication protocol and the data format for receiving content and authorisation files 3. Especially for the collection of ticketing data, the standard puts forward clear basic requirements for data interfaces, mandating that the platform achieve real-time and seamless connection with the national performance ticketing information collection and service system 2. From the perspective of compliance strategy, this means that ticketing platforms must break the original closed business loop and fully open the underlying data flow to regulatory agencies. If the platform fails to complete the reconstruction of the internal system and the joint debugging and docking of the government interface in strict accordance with the WH/T 93-2021 standard, it will face the fatal risk of being unable to obtain legal ticket sales qualification certification, or even being ordered to suspend operations for rectification in a cross-department joint law enforcement operation. The transparency of underlying data forms the technical and physical basis for all subsequent compliance reviews and risk control management.
2. Access barriers for platform entities and stepped substantive review obligations
As a bridge connecting the supply of cultural performance products and massive consumer demand, the audit responsibilities assumed by ticketing platforms under the legal framework are showing an obvious step-by-step strengthening trend. This responsibility not only requires the platform to "keep itself clean" and ensure that the licenses are complete, but also requires it to have "a sharp eye" to conduct substantial and penetrating verification of the qualifications of the co-organizers, the legality of the performances and even the value orientation of the content.
1\. Qualification compliance: the platform’s own administrative licensing and subject qualifications
At the most basic level of compliance, ticketing platforms must fulfill extremely strict qualification reviews and licence operating obligations. The platform itself first needs to obtain a qualification licence issued by the local culture and tourism administrative department to engage in commercial performance ticketing operations. Cultural market law enforcement reports over the years have repeatedly confirmed that unqualified ticket sales or operating beyond the scope are high-voltage lines with zero tolerance for regulatory authorities.
Among the major cases in the commercial performance market reported by the Ministry of Culture and Tourism in 2018, qualification violations were common. For example, Guangxi Surprise Culture Media Co., Ltd. openly sells commercial performance tickets on third-party e-commerce platforms such as "Taobao" even though it does not have the qualifications to operate commercial performance ticketing at all. In response, the New Bureau of Culture, Radio and Television of Nanning City, Guangxi Zhuang Autonomous Region, in accordance with the clear provisions of Article 43 of the "Regulations on the Administration of Commercial Performances", imposed a severe administrative penalty on the enterprise, confiscating 18,911 yuan of illegal income and imposing a high fine of 151,288 yuan. 5 Similarly, in the case of a famous singer's concert in Chengdu supervised by the Sichuan Provincial Department of Culture, a number of Internet technology companies, including Henan Shengxing Cultural Communication Co., Ltd. and Beijing Youpiao Technology Co., Ltd., were involved in commercial performance ticketing activities without authorization, or sold tickets without the legal authorisation of the performance organizer. The case was intensively investigated and 9 units involved were fined a total of 255,000 yuan. 5 These painful lessons warn ticketing platforms that business expansion must be based on the boundaries of administrative permission. Any sidestepping behaviour that attempts to circumvent qualification review through "underwriting", "purchasing agency" and other names will face severe administrative sanctions.
2\. Formal review obligations: Prevent forged approval documents and illegal invoicing
After establishing its own qualifications and compliance, the platform's formal review of performance organizers and performance project documents constitutes the second line of defense. According to current regulations, ticketing platforms must verify basic legal documents such as the performance organizer's "Commercial Performance License", the performance approval document issued by the local cultural department, and the safety plan for large-scale mass events before officially providing ticketing services. 6 If the platform fails to fulfill this prudent verification obligation and blindly opens a ticket sales channel, it will inevitably fall into the quagmire of joint violations.
A very representative case of vicious violations occurred during the preparations for a concert at the Helan Mountain Stadium in Yinchuan City, Ningxia Hui Autonomous Region. In this case, the so-called "invitation letter issued by the Propaganda Department of the Yinchuan Municipal Committee of the Communist Party of China to Jacky Cheung" provided by Beijing Dongqi Culture Media Co., Ltd. to the Ningxia Department of Culture was actually forged and of extremely egregious nature. The Yinchuan Municipal Public Security Bureau quickly opened a case for investigation and took criminal detention measures against the suspect. 5 Before the project received final legal approval, the Xi'an branch of Beijing Red Horse Media and Culture Development Co., Ltd. could not wait to sell tickets in advance without authorization. This serious violation of the approval process directly led to the legal investigation by the Yinchuan City Cultural Market Comprehensive Law Enforcement Team, and it was planned to impose severe administrative penalties in accordance with the law5. This case profoundly demonstrates that the “invoicing switch” in the ticketing system must be hard-bound at the physical level with the government’s final approval documents, and the business compliance risk control team within the platform must assume the unshirkable responsibility for cross-verification of the integrity of the authorisation chain and the authenticity of government documents.
3\. Extension of substantive examination: content-oriented control and blocking of new infringements
With the diversified iteration of cultural and entertainment industry forms, formal review that only focuses on checking red-headed documents is far from being able to meet current compliance demands. The law enforcement guidance in recent years has clearly shown that ticketing platforms also have substantial responsibility for the value orientation of performance content, the maintenance of public order and good customs, and the protection of intellectual property rights.
Table 1: Typical risk mapping and response strategies for substantive review obligations of performing arts ticketing platforms
| Risk areas | Typical violations and law enforcement cases | Platform compliance review and response strategy matrix |
|---|---|---|
| Performer and Qualification Black Hole | The venue has no qualifications or the artist has bad records. In the 2021 notice, a bar in Xi'an, Shaanxi and a bar in Jincheng, Shanxi, without obtaining a "commercial performance license" and without entrusting a qualified agency, held performances involving bad artists (such as Wang PGxxx) or high-risk Internet celebrities without authorization, which caused adverse social repercussions and were both fined and equipment confiscated7. | Establish a dynamic verification blacklist database of cooperation venues and artist qualifications. The highest level of manual review will be implemented for underground performances involving high-risk or artists with bad records to prevent the platform from becoming a hotbed for unlicensed operations. |
| Public order and good morals and political red lines | The content of the performance is vulgar or illegal political themes are used to make profits. A company in Tianjin held a "binding party" in a bar, including tying, dripping wax and other sexual abuse behaviors that clearly endanger social morality; a restaurant in Huaibei, Anhui organized an "August 1st" party with vulgar content; some businesses used illegal ticket sales to make profits by "celebrating the 100th anniversary of the founding of the Party"7. | Strengthen the semantic and image review of online promotional materials, event names, and offline performance plans; veto any gimmicks that are obviously vulgar, sexually suggestive, or inappropriately borrowed from political nodes for marketing. |
| Intellectual Property and AI New Infringement | The organizer is not authorised to perform; use AI face-changing technology or virtual idols to perform infringing performances (such as using celebrity images to generate "XXX March" without authorization) 6. | Strictly implement Article 38 of the Copyright Law and verify the legal authorisation certification chain of the performance content. Conduct substantive review of posters and AI-generated materials, and allowing them to sell tickets through the platform despite knowing the infringement will constitute joint infringement 6. |
| Ticket fraud and malicious overbooking | The organizer falsely increased the number of venue seats and oversold tickets, resulting in a large number of spectators being unable to enter the venue after arriving at the venue (such as a secret unbroadcast event in 2025), triggering group rights protection and public safety incidents 6. | Connect to the real physical seat map data base of the venue and monitor the ticketing port data in real time. The circuit breaker warning mechanism 6 will be triggered immediately for abnormal sales behaviour (such as massive ticket hoarding by a single account, and the overall sales rate exceeds the venue's approved carrying capacity). |
From the above analysis, it can be seen that the compliance system of the ticketing platform must move from traditional "backend support" to "frontend blocking". When potential content risks, intellectual property flaws, or signs of fraud are discovered, they must have the decisiveness to dare to refuse to provide ticketing services and promptly report the whistle to the competent authorities.
3. Prevent "scalpers" from scalping votes and the in-depth game of strong real-name technology
The most core pain point faced by the performance ticketing market for a long time and the most criticized by the society is the high degree of monopoly of ticket sources and the vicious speculation of high prices in the secondary market. As regulatory policies continue to tighten and public opinion pressure continues to rise, preventing and cracking down on scalpers has evolved from a mere market self-discipline to an important part of rigid administrative compliance requirements and public safety governance.
1\. Bottom line defence and source control of ticket disclosure ratio
In order to fundamentally protect the fair ticket purchase rights of ordinary consumers, regulatory authorities have set a red line that cannot be tested on the proportion of tickets sold to the market. Early policy documents have clearly stipulated that the number of commercial performance tickets sold to the market must not be less than 70% of the number of audiences approved by the public security department 8 . The original intention of this ratio restriction policy is to greatly squeeze the living space of "scalpers" who can seize large amounts of tickets through non-public internal channels. In the unspoken rules of the performing arts market, in addition to publicly sold tickets, the number of work tickets, free tickets, anti-increase tickets and other channels reserved by the organizer is extremely flexible and the flow path is extremely private. It has always been the main ticket source library for "scalpers" to hoard 9.
In the compliance control of actual operations, the ticketing platform must not only ensure that its agent sales are completely open and transparent, but also need to cooperate with the regulatory authorities to supervise the organizers through the hard locking and data reporting mechanism of the underlying system to ensure that the public sales ratio meets legal standards. Any act of reserving high-quality seats and reselling them to the secondary market through secret operations is a serious compliance breach. Strengthening the traceability management of non-public ticket circulation paths is a key breaking point to standardize the order of the overall ticket market 9.
2\. Comprehensive implementation of “strong real-name system” and upgrading of technical risk control
Among the many means to curb "scalper" ticket speculation, real-name ticket purchase is recognized as the most core and effective system of defense. From the early "real-name ticket purchase" that only required filling in the ID number, it has gradually evolved to today's strict "strong real-name system (the combination of person, certificate, and ticket)", and compliance requirements have made a qualitative leap in practice. The "strong real-name system" not only requires that the audience provide true and valid identity information during the ticket purchase process, but also requires that at the performance site, the audience must hold the valid physical ID they filled out when purchasing the ticket, and perform biometric comparison through facial recognition equipment. Only when the face, ID, and ticket information are completely consistent can admission be allowed 9. At present, many large-scale and popular performance projects, including first-tier cities such as Beijing, Shanghai, and Hangzhou, have routinely provided and compulsorily applied such strong real-name verification services9.
However, the full implementation of the real-name system for performance tickets will not be achieved overnight. The platform must strategically pass three extremely difficult hurdles: technical hurdles, efficiency hurdles and management hurdles 8.
The first is technical barrier and intelligent risk control interception. In the face of the increasingly rampant illegal ticket fraud software, ticketing platforms must invest huge funds and technical resources to carry out large-scale upgrades of existing software and hardware infrastructure8. On the front-end of ticket sales, the platform needs to deploy advanced traffic cleaning technology, integrate complex security components to perform multiple encryption on all order requests, and accurately identify real human users and malicious ticket-grabbing robots in milliseconds in real time. According to authoritative data, the current interception rate of the leading ticketing platform against malware for ticket fraud has successfully reached 99%9. In addition, the platform also needs to rely on big data to establish a dynamic "scalper" risk control blacklist library, perform cross calculations based on abnormal account behaviour traces, high-frequency mobile phone numbers, and black and gray production certificate number matching, and implement real-time blocking of order requests from abnormal devices and suspicious accounts. Taking a mainstream ticketing platform as an example, in just a few months from February to June 2023, its system successfully intercepted up to 52 million orders from "scalper" attacks 9 .
Secondly, efficiency is closely related to the emergency plan for large passenger flow. The complex process of real-name ticket verification will inevitably lead to a significant extension of the verification and admission time for a single audience. In large-scale star concerts with tens of thousands of people, it is easy to form a high-density "flood" of people outside the venue. This is not only a severe test of the feasibility of the real-name system, but also creates huge public safety hazards such as crowding and stampedes8. From the perspective of security compliance for large-scale events, ticketing platforms must not limit their responsibilities to online ticket sales, but must be deeply involved in the planning of offline ticket checking. The platform should assist the organizer to establish a large passenger flow early warning mechanism as early as possible. In the ticketing process, pre-sale services and multi-site diversion can be explored. In the ticket checking process, high-throughput gate equipment needs to be deployed to ensure that the flow of people is absolutely smooth, and the optimal solution is found between the pursuit of fast admission and error-free verification 8.
Finally, there is the bottom line of management and personal information protection. Although the implementation of the real-name system can effectively curb vote scalping, it is not an impeccable "iron wall". If the platform is not managed well, it may also leave opportunities for "scalpers" to take advantage of it. 8 What is even more serious is that when collecting audience names, ID numbers, and even fingerprint verification, face recognition and other core biometric features, the platform faces extremely huge pressure to protect personal information and comply with regulations 8 . According to the strict provisions of the "Personal Information Protection Law", the platform must follow the three principles of "individual consent", "minimum necessity" and "purpose limitation", and establish a bank-level data encryption transmission and desensitized storage mechanism to ensure the absolute safety of the audience's personal privacy information throughout the life cycle of collection, use, comparison and destruction after the performance. Any large-scale data leakage caused by system vulnerabilities will result in devastating administrative penalties and huge civil claims.
3\. Multi-departmental joint supervision and full-link crackdown on black and gray industry chains
In the face of scalpers with intertwined interests, it is obviously difficult to rely solely on the technical prevention of ticketing platforms. On April 26, 2023, the Ministry of Culture and Tourism issued the "Notice on Further Strengthening the Management of the Performance Market and Regulating the Order of the Performance Market", which clearly issued instructions requiring local cultural and tourism administrative departments to effectively regulate the market order, list commercial performances with extremely high social attention and extremely tight ticket supply and demand as key supervision objects, and cooperate with local public security, market supervision and other powerful law enforcement departments to crack down on illegal activities such as "cattle scalpers" and ticket speculation in accordance with the law to effectively protect the legitimate rights and interests of consumers 9.
In this context of collaborative governance by multiple ministries and commissions, the compliance obligations of ticketing platforms have been extended from passive acceptance of inspections to active "government-enterprise collaboration and assistance in law enforcement." The platform must open a conspicuous and convenient channel for reporting “scalper” clues on the user side, and collect extensive social supervision feedback9. More importantly, the platform needs to give full play to its technical advantages in mastering underlying big data, actively cooperate with the public security agencies, and accurately identify the IP traceability and abnormal fund settlement network of machine ticket fraud through penetrating analysis of abnormal ticket purchase data packets, so as to provide irrefutable electronic evidence clues for the police to detect cross-regional illegal ticket scalping cases and destroy black industry gangs 9.
In recent years, such joint attacks have achieved remarkable results. In the special rectification operation during the National Day holiday carried out by the Beijing Cultural Market Comprehensive Law Enforcement Corps in 2024, the Corps focused its attention on the reselling of online ticketing products involving Tiananmen Square, the Palace Museum and other popular scenic spots. At the same time, it joined forces with the public security department to crack down on ticket scalpers, and successfully investigated and dealt with 16 people involved in online ticket scalping, and eliminated 4 travel-related fraud gangs in one fell swoop. In a typical law enforcement case before this, Changzhou Qilixiang Ticketing Co., Ltd. organized a large number of "auction agents" to snap up tickets, and purchased them from others at a premium for hoarding and reselling performance tickets, involving as many as 812 tickets for a famous singer's concert. Because it was suspected of engaging in commercial performance ticketing activities without authorization, it eventually faced severe sanctions of confiscation of illegal income and high fines. 5 These iron-fisted law enforcement cases have sent a strong signal to the entire industry: any vote scalping behaviour that wanders in the gray area will be traced and severely punished throughout the entire chain.
4. New Internet Compliance Paradigm of Algorithmic Governance and Data Transparency
In the digital deep-water area, ticketing platforms are not only distribution channels for cultural performance products, but also Internet technology companies that rely heavily on algorithms for resource allocation. Therefore, the platform not only needs to comply with traditional cultural performance market regulations, but also must place its huge system under the country's grand framework on Internet information services and data security governance for a comprehensive physical examination.
The "Internet Information Service Algorithm Recommendation Management Regulations" (hereinafter referred to as the "Management Regulations"), which was reviewed and approved at the office meeting of the Cyberspace Administration of China in November 2021 and jointly issued by the Ministry of Industry and Information Technology, the Ministry of Public Security and the State Administration for Market Regulation, and will be implemented from March 1, 2022, has put a highly binding "tightening curse" on performing arts ticketing platforms, including Damai, Maoyan, etc., that highly rely on algorithm distribution and traffic scheduling 11.
The "Management Regulations" are solidly supported by higher-level laws such as the "Cybersecurity Law", "Data Security Law", and "Personal Information Protection Law", and aim to deeply respond to prominent social problems such as algorithmic discrimination, "big data familiarity" and induced addiction caused by the increasing popularity of algorithm applications, so as to maintain normal market order and social fairness and justice 12. The scope of application of the "Administrative Regulations" is extremely broad, and any entity that applies algorithm recommendation technology to provide information services within the country is subject to its strict jurisdiction. For ticketing platforms, the personalized push categories (such as recommending specific concerts based on users’ listening habits), sorting and selection categories (such as the homepage display of popular performances), retrieval and filtering categories (such as remaining ticket monitoring and automatic screening), and scheduling decision-making categories (such as the queuing sequence for out-of-stock registration and the allocation algorithm for waitlisted ticket purchase qualifications) that are widely used in daily operations all fall within the scope of this regulation without any suspense 12.
Under this framework, ticketing platforms face extremely stringent algorithm compliance and filing information disclosure obligations:
Table 2: Performing Arts Ticketing Platform Algorithm Recommendation Compliance Review Core Element Matrix
| Compliance review dimensions | Specific regulatory requirements and legal basis | Ticketing platform practical implementation strategy |
|---|---|---|
| Algorithm Security Assessment and Filing | Algorithm recommendation service providers with public opinion attributes or social mobilization capabilities should proactively conduct security assessments in accordance with relevant national regulations 13. | For leading ticketing platforms covering tens of millions of users, algorithm filings must be submitted to the Internet Information Department to clarify the core logic of popular performance ticket distribution algorithms and prove that they do not have the risk of mobilizing to cause social mass incidents. |
| Algorithmic fairness and anti-discrimination | It is strictly prohibited to use algorithms to implement "big data killing" or conduct unreasonable price discrimination 12. | Ensure that tickets for the same event and the same area are at the same time node, showing completely consistent prices and ticket purchase probabilities for new and old users, and users with different spending power labels, and eliminating dynamic premiums and implicit price discrimination. |
| Log retention and traceability assistance | Algorithm recommendation service providers should retain network logs in accordance with the law, and cooperate with network information, telecommunications, public security, market supervision and other departments to carry out security assessment and supervision and inspection work, and provide necessary technical and data support 13. | Establish an independent algorithm log storage cluster and retain queuing, lottery and waitlist allocation records for at least six months. When responding to consumer complaints or regulatory inquiries about "black-box operations", it can provide interpretable proof of the algorithm's operation trajectory. |
| Transparency and users’ right to know | Protect the legitimate rights and interests of netizens and establish and improve information service specifications 12. | In the user registration agreement and ticket purchase instructions, use easy-to-understand language to disclose to consumers what recommendation algorithm the platform uses, and provide a convenient option to turn off personalized recommendations. |
It can be said that algorithm compliance requires ticketing platforms to completely bid farewell to the past "algorithm black box" era, put the underlying technical logic under the sun, and accept public scrutiny and penetrating audit verification by regulatory authorities.
5. Consumer Rights Protection Deep Water Area: Reconstruction and Systemic Breakthrough of the Return, Transfer, and Change Mechanism
If the real-name system is a strong shield against scalpers, while this shield is effective, it has also unexpectedly left a deep scar in the field of consumer rights protection. With the implementation of the “strong real-name system” across the country, the core pain point of the performance market has undergone a dramatic and violent shift in a very short period of time: from the “difficulty in obtaining tickets” that consumers generally complained about two years ago, it has rapidly evolved into the “difficulty in refunding tickets” that has caused massive disputes today. 14 The ticketing platform’s compliance flaws and lag in the design of refund and exchange rules have irreversibly become the hardest hit area, triggering large-scale consumer complaints, media exposure and even group legal proceedings.
1\. The loss of legal validity and public opinion backlash of the industry practice of “no refunds”
Looking back at the development history of China's performance market, the sales pages of exhibition tickets, dramas, operas, concerts and other performance tickets have long been directly marked with "returns and exchanges not supported", or "non-refundable" in small print on the final payment page. These areas have once become the absolute hardest hit areas of the unspoken rule of "no refunds"15. Research by Chen Yinjiang, a well-known consumer rights protection expert, pointed out that for a long time in the past, cultural performance activities were generally regarded by society as high-end consumption that was not necessary for life. In addition, the cultural performance market was still in the cultivation stage at that time, and consumer tolerance was high. In order to protect the development of the industry, regulatory authorities also adopted a cautious and tolerant attitude. As a result, the so-called "no refunds" industry practice has been established over the years 15.
However, time has changed, and now entertainment and cultural consumption has been deeply integrated into the daily consumption structure of the general public, and the strong real-name system has completely cut off consumers' last resort to privately transfer tickets to others when faced with emergencies. In this extremely unequal game, if the platform and the organizer still adhere to the old rule of "no refund, no exchange", it will obviously become a pale excuse to shirk legal responsibilities15.
The "Analysis of Complaints Accepted by National Consumers Association Organizations" report released by the China Consumers Association (China Consumers Association) in the first half of 2025 disclosed a set of shocking data: the number of concert-related complaints continued to explode in the first half of the year, and the proportion of them specifically involving refund claims was astonishingly over 90% 16. In fact, as early as the first half of 2023, the huge controversy over "difficulty in refunding tickets for offline performances" has topped the China Consumers Association's consumer rights protection public opinion hotspot list 16. According to the "China Performance Ticketing Industry Development Trend Report 2023-2025" released by third-party organization iResearch and Black Cat Complaints 2024 data, among more than 77,000 entertainment ticketing complaints, up to 46.6% of the complaints were directly directed at performance ticketing, and the core focus of half of the disputes was ticket refunds14.
From the perspective of strict legal application, using high or even full ticket prices as the price for consumers to cancel orders is suspected of constituting a typical "overlord clause". Zhang Yuxia, a member of the Shanghai Municipal People's Political Consultative Conference and public interest lawyer of the Municipal Consumer Protection Committee, clearly pointed out that according to the authoritative provisions of Article 585 of the Civil Code of the People's Republic of China: If the liquidated damages agreed by the parties are excessively higher than the losses caused, the people's court or arbitration institution may appropriately reduce it according to the request of the parties15. Currently, even if some ticketing platforms are forced to allow refunds, their unilaterally set refund fees are still as high as 30% to 50% of the ticket price 15 . In judicial practice, if the platform or organizer cannot provide detailed and irrefutable financial evidence to prove that it has incurred "upfront irreversible cost expenditures" or actual economic losses equivalent to this proportion due to the refund of a single ticket, it will be difficult for such highly punitive and high fees to be supported by the legality of the court, and consumers have every right to request that they be revoked or significantly reduced. 14
2\. The chaotic dilemma between mandatory instructions at the policy level and platform implementation
In the face of increasingly intensifying conflicts, policy intervention at the national level has been decisive. In September 2023, the Ministry of Culture and Tourism and the Ministry of Public Security jointly issued the landmark "Notice on Further Strengthening the Standardized Management of Large-scale Commercial Performance Activities to Promote the Healthy and Orderly Development of the Performance Market." The document clearly requires in unquestionable terms: "Performance organizers should establish a refund mechanism for large-scale performance events, set reasonable tiered refund fees, and effectively protect the legitimate refund rights of ticket buyers." 15 Many industry experts have unanimously called for the performing arts industry to humbly learn from the tiered refund mechanisms of mature public transportation industries such as aviation and railways to make rules more transparent and predictable 15.
However, the ideal is full and the reality is skinny. This well-intentioned policy encountered serious implementation distortions and resistance in the process of penetrating into terminal platforms and organizers. In the actual process of consumer rights protection, the chaos of platform refund paths is extremely hidden and unclear, the application process is cumbersome and complicated, and the rules between different platforms and even between different projects on the same platform are still shocking15.
For example, when Mr. Qin, a citizen of Nanjing, Jiangsu Province, purchased tickets for a celebrity concert, he found that the ticket issuance date displayed on the page was July 11, but the refund rules absurdly stated that "no refunds will be accepted after July 3." This clause, which obviously violates the logic of time and the principle of fairness, is staggering 15. For another example, when Ms. Wang from Xi’an, Shaanxi applied for a refund for her family’s tickets for a star’s concert in Tianjin on April 14, she was helplessly discovered that the Jinan and Suzhou stations where the artist was touring generously supported 24-hour or 48-hour unconditional refunds for both the first and second openings. However, the Tianjin station was forcefully set by the organizer to “not support refunds” 15 . The fragmented rules of "same stars, different fates, same performances, different rights" have completely exposed the shirking of responsibilities between the ticketing platform and local organizers. Platforms habitually leave the blame to local organizers, but in the context of the Consumer Rights Protection Law, ticketing platforms, as the core party that directly collects full fares from consumers and provides front-end format contracts, cannot escape the fate of becoming the first responsible party for administrative complaints and civil litigation.
3\. Systematic way to break the situation: refined management of tiered refunds and macro construction of the official transfer platform
Zheng Ning, director of the Cultural and Legal Research Centre of the School of Cultural Industry Management of Communication University of China, profoundly pointed out that the strong real-name system has played an important role in curbing scalpers' speculation and safeguarding fairness, and has become a basic principle for large-scale performances. However, it also unilaterally transfers unforeseen performance risks (such as sudden illness, traffic delays, etc.) to consumers, causing the trust relationship between consumers and ticketing platforms to be extremely tense 14. To resolve this structural contradiction, we must explore and establish a more complete and highly flexible ticket circulation mechanism from the macro perspective of systemic change and on the absolute premise of adhering to the real-name verification system 14.
Table 3: Reconstruction of the return mechanism and compliance path for the performing arts ticketing market
| Breakthrough dimensions and strategic direction | Specific operational mechanism design and technical support | Platform compliance value and market expectations |
|---|---|---|
| Promote an industry-wide standardized tiered refund system | Work together with industry associations to issue unified detailed rules based on the project preparation cycle (for example: full refund free of charge within 48 hours after ticket issuance; 10% handling fee deducted 15 days before the show; 30% deducted 7 days before the show; no refunds within 48 hours before the show) 15. | End the chaos of fragmented rules in various places, greatly reduce the risk of judicial litigation of "overlord clauses" faced by the platform, and give consumers reasonable expectation management. |
| Build an officially recognized high-transparency ticket transfer system | Following the mature experience of large-scale sports events such as the Olympic Games, the official second-hand ticket transfer module is embedded within the ticketing platform. Users who are unable to attend the performance for any reason are allowed to return the tickets to the official ticket pool at the original price (or set a very low handling fee) or directly transfer them to relatives and friends (the transferee’s identity information needs to be re-entered for real-name replacement) 14. | More than 80% of consumers surveyed are highly looking forward to this “one-click ticket transfer” service 14. It not only ensures the absolute authenticity and reliability of ticket sources, completely eliminates premium disputes and fraud in off-site private transactions, but also cleverly revitalizes stagnant ticket sources, achieving a perfect balance between preventing scalpers and protecting rights and interests. |
| Introduction of exemption channels for force majeure and special circumstances | For users who are unable to attend performances due to sudden major illnesses, changes in immediate family members, or force majeure and extreme weather, the platform should establish a manual review channel for specialists. After the user submits a true and valid certificate of diagnosis from a tertiary hospital, a full refund or an exemption will be given. | Demonstrate corporate social responsibility, make up for the coldness of mechanical rules, and effectively calm major negative online public opinions caused by extreme cases. |
Through refined governance methods, ticketing platforms can completely crack down on scalpers and ensure market fairness while retaining the consumer vitality of the market, thereby delivering a compliant and high-scoring answer sheet in the big test of safeguarding the legitimate rights and interests of consumers.
6. Cross-border derivative risks and joint law enforcement trends in the context of deep integration of culture and tourism
With the continued prosperity of the performing arts market and the continuous evolution of business formats, ticket sales alone can no longer satisfy the platform's ambition to pursue increased profits. Many leading ticketing platforms have begun to rely on huge traffic entrances to expand into the upstream and downstream of the industry chain, frequently launching combined cultural and tourism derivative products such as "performance tickets + high-end hotels", "performance tickets + surrounding in-depth tours", and "music festival camping packages". This kind of cross-border operation not only broadens the business boundaries, but also makes the ticketing platform inevitably touch the strict jurisdiction of tourism regulations, introducing a new cross-border compliance risk variable.
Looking at the special rectification operations for the capital's cultural and tourism market order during the National Day holiday uniformly deployed by the Beijing Cultural Market Comprehensive Law Enforcement Corps in 2024, the deterrence and penetrating power of joint law enforcement are clearly revealed. In the field of combating false propaganda on the Internet, the Law Enforcement Corps coordinated the forces of public security, transportation and other departments, and vigorously investigated and dealt with more than ten vicious cases of travel agencies (such as Longzhiyi and Shengjing Travel Agency) using social media and online platforms to publish false travel information10. One typical case shows that a salesperson from a Shengjing travel agency rashly collected travel deposits without clearly informing tourists that ticket reservations for the Forbidden City were restricted and highly uncertain. In the end, tourists were unable to enter the Forbidden City due to the failure to reserve tickets, which directly violated the relevant provisions of the Tourism Law. The travel agency and the person directly responsible were subjected to severe administrative fines and confiscation of illegal income. 10 In addition, many local cultural and tourism bureaus have also mercilessly punished unlicensed tour guides for providing explanation services without permission (such as the case of Liu Mouguo and Bai Mouling) and intimidating and coercing tourists into shopping. 17
Drawing our attention back to the entertainment and ticketing industry, these cultural and tourism law enforcement cases have all sounded a deafening compliance alarm. Ticketing platforms must strictly perform double or even multiple compliance reviews when designing and listing "Ticket +" cross-border travel products. On the one hand, the platform must require the cooperative travel agency to provide a legal "Travel Agency Business License" to ensure that the ground pick-up personnel have nationally certified tour guide qualifications; on the other hand, in the process of product promotion and page solicitation, the platform must bear strict joint and several guarantee responsibilities for the certainty of service commitments (such as whether to ensure that you can stay in a designated star hotel, whether to provide an exclusive bus transfer), and it is strictly prohibited to use exaggerated, highly misleading and false promotional copy 10. Anyone who attempts to use the platform's own brand endorsement but transfers actual contract performance risks to inferior suppliers will face fraud charges of "refund one and compensate three" under the Consumer Rights Protection Law and high penalties from the cultural and tourism authorities.
Not only that, under the overall strategy of supporting the construction of a "performing city", the cultural and tourism law enforcement departments are also constantly strengthening their penetrating supervision of the operating nature of performance venues. The Beijing Culture and Tourism Law Enforcement Corps has successively investigated and dealt with the case of "Huahai Livehouse" in Chaoyang District engaging in entertainment venue operations without authorization, and the case of the "Huahai Ticketing" platform selling unapproved commercial performance tickets without authorization10. This further warns ticketing platforms that even for small-scale, down-market or online livehouse performances and online live performances, they must not take any chances in the qualification review. They must extend their compliance tentacles to the very end of the industry and completely cut off the ticket monetization links for any non-compliant performances.
Conclusion and Strategic Outlook
Looking back at the historical node of 2026, China's performing arts ticketing market is undergoing a profound transformation from "barbaric horse racing" to "refined operation under the rule of law." Regulatory authorities are flexibly and majestic wielding the triple sword of administrative law enforcement, industry technical standards and comprehensive Internet governance, posing an unprecedented extreme test to the comprehensive compliance capabilities and crisis response mechanisms of ticketing platforms. Faced with the crazy counterattack of hidden scalpers, the general awakening of consumers’ awareness of rights protection, and the exponential improvement in the effectiveness of joint supervision across ministries and commissions, if ticketing platforms continue to indulge in the simple “traffic arbitrage” and “exemption from responsibility” thinking, they will be ruthlessly eliminated in the fierce market waves.
Facing the future, ticketing platforms must realize the upgrading of compliance concepts and strategic reconstruction. Enterprises should transform the compliance review system from a passive defence of the cost centre into a core business competitiveness that drives the steady development of the enterprise and wins the trust of the public. First of all, the intelligent substantive examination technology platform should be comprehensively upgraded, using OCR recognition, natural language processing and real-time docking of large government databases to build a risk map of performance entities and intellectual property rights covering the entire network. Secondly, we will reconstruct the refund and change mechanism with the determination of a strong man, relying on blockchain and smart contract technology to embed a rigid and transparent tiered refund model in the entire ticket purchase process, actively strive for policy pilots, and lead the establishment of an official and standardized secondary ticket circulation market. Finally, the platform should actively integrate into the country's grand strategy of cultural security and data governance, refine the massive internal risk control interception data into high-value regulatory intelligence, and build a normalized and seamless intelligence sharing and joint attack mechanism with public security, municipal supervision, culture and tourism and other departments.
Only by deeply engraving awe of laws and regulations into every line of the underlying algorithm code, and integrating careful protection of consumer rights and interests into every detail of the business process, can China's performing arts ticketing platform build an indestructible strategic moat amidst complex macro-policies and a rapidly changing market environment, and provide the most solid, reliable and clear digital infrastructure support for the continued prosperity, healthy and orderly Chinese cultural and performing arts industry.
Works Cited
1. Cultural Industry Standard WH/T 93-2021 Performance Ticketing System Services and Technical Specifications, accessed on May 16, 2026, https://zwgk.mct.gov.cn/zfxxgkml/hybz/202108/t20210806\_926992.html
2. China·Shandan-The second batch of cultural and tourism industry standards released in 2021, accessed on May 16, 2026, https://www.shandan.gov.cn/zfxxgk/fdzdgknr/jczwgkbzml/ggwh/ggwhty\_7259/202108/t20210809\_687000\_ghb.htm l
3. Cultural Industry Standard WH/T 93-2021 Performance Ticketing System Services and Technical Specifications \- Tourism Planning, accessed on May 16, 2026, http://www.gxwhly.net/html/2021/hy\_0823/75.html
4. Announcement of the Ministry of Culture and Tourism on the release of the second batch of cultural and tourism industry standards in 2021, accessed on May 16, 2026, https://zwgk.mct.gov.cn/zfxxgkml/hybz/202108/t20210806\_926989.html
5. The Ministry of Culture and Tourism strictly inspects and strictly controls the commercial performance market \- Ministry of Culture and Tourism of the People's Republic of China, accessed on May 16, 2026, [https://www.mct.gov.cn/whzx/whyw/201806/t20180613\_833337.htm](https:/
/www.mct.gov.cn/whzx/whyw/201806/t20180613_833337.htm)
6. What kind of audit responsibilities does the ticketing platform need to bear for such infringing performances? \- Sina Finance, accessed May 16, 2026, https://cj.sina.cn/articles/view/7879776328/1d5abd84806801e9kw?froms=ggmp
7. The Ministry of Culture and Tourism reported 5 typical cases this year where bars were fined for inviting an internet celebrity to perform without permission \- Sina News, accessed on May 16, 2026, https://news.sina.cn/2021-12-03/detail-ikyakumx1840426.d.html
8. Legal Daily: The real-name system for performance tickets must pass three hurdles \- People's Daily Online, accessed on May 16, 2026, http://opinion.people.com.cn/n1/2017/0811/c1003-29464248.html
9. The platform has cracked down hard on "scalpers" to get off to a good start. To maintain the health of the performance market, market combination is needed - Xinhuanet, accessed on May 16, 2026, http://www.news.cn/ent/20230707/a36478eea47643c494557a65f75347fa/c.html
10. [Qianlong.com] Beijing severely cracks down on illegal and disruptive behaviors in the cultural tourism market and reports 9 typical cases, accessed on May 16, 2026, [https://whsczfzd.beijing.gov.cn/ztzl/mtzs/202412/t20241224
\_3972821.html](https://whsczfzd.beijing.gov.cn/ztzl/mtzs/202412/t20241224_3972821.html)
11. Internet Information Service Algorithm Recommendation Management Regulations \- Xinhuanet, accessed May 16, 2026, http://www.news.cn/politics/2022-01/04/c\_1128230224.htm
12. Interpretation of key points of the "Provisions on the Management of Algorithm Recommendations for Internet Information Services" \-Junhe, accessed on May 16, 2026, https://www.junhe.com/law-reviews/1651
13. "Internet Information Service Algorithm Recommendation Management Regulations" Answers to Reporters' Questions \- Communist Party Member Network, accessed on May 16, 2026, https://www.12371.cn/2022/01/04/ARTI1641267591024417.shtml
14. Improve the mechanism to resolve the difficulty of refunding tickets for performances, accessed on May 16, 2026, http://paper.ce.cn/pc/content/202604/20/content\_331345.html
15. It is difficult to refund performance tickets. How to solve the dilemma? \- Xinhua Daily, accessed May 16, 2026, https://www.xhby.net/content/s68a98340e4b03d79462075cd.html
16. China News Awards Public Opinion Supervision Report (New Media) "How to Solve the Dilemma of Refunding Performance Tickets" \- Guangming.com, visit time
As of May 16, 2026, https://news.gmw.cn/2026-05/13/content\_38763383.htm
17. The Ministry of Culture and Tourism announced the second batch of typical cases of compulsory consumption in the tourism market in 2026 \-Xinhuanet Client, accessed on May 16, 2026, https://app.xinhuanet.com/news/article.html?articleId=202605097a5942d2a5784dfa897ee089c1e87de5
18. The Ministry of Culture and Tourism announced the first batch of typical cases of compulsory consumption in the tourism market in 2026 \-Xinhuanet Client, accessed on May 16, 2026, https://app.xinhuanet.com/news/article.html?articleId=b664ac65e64e3b98db3484fd7b4029cd