China Food Delivery: Not Just a Soft Draft: Disclosure Rules Could Cool the Food Delivery Subsidy War

Research evidence excerpt

China Food Delivery: Not Just a Soft Draft: Disclosure Rules Could Cool the Food Delivery Subsidy War

Alex Yao Asia Pacific Equity Research

(86 21) 6106 6505 18 June 2026

alex.yao@jpmorgan.com

Valuation: scenario skew improves, estimates unchanged

We keep ratings and estimates unchanged. The draft is still open for comment, and the final wording will matter.

Our Meituan scenario set remains:

Table 4: Meituan scenario analysis

Scenario PT Description

Bull Around HKD128 Rationalized competition, stronger profit-pool recovery

Base Around HKD92 Subsidy pressure eases, but cost floor remains higher

Bear Around HKD51 Prolonged capital-funded competition and weaker delivery profit pool

Source: J.P. Morgan.

The draft does not change the model mechanically today. It changes the probability distribution. A credible shift in the

“binding vs cosmetic” debate would justify moving some weight out of the bear case and into the base and bull cases.

Illustratively, moving around ten points of probability weight away from the bear case would lift our blended PT into the

low-to-mid HKD90s.

That is a continuation of our prior framework, not a new valuation thesis. Bear-case probability had already declined from

our April deep dive to the 1Q26 results update. The SAMR draft reinforces that direction but does not complete the

argument. We would wait for final text and 3Q26 subsidy evidence before making formal estimate changes.

What could make us wrong?

Final wording allows group-level profit

This is the most important risk. If the final rule explicitly allows platforms to fund subsidies from group-level operating

profit, the asymmetry weakens. Alibaba would retain greater flexibility to support food-delivery investment, and Meituan’s

strategic benefit would be smaller.

Enforcement is soft