Abstract: The institutional evolution of the market access threshold of the off-campus online training industry reflects the Internet economic context and the microcosm of the reform of the administrative approval system. Education administrative organs try to replace the regulatory effect of ex-ante supervision with an interim and ex-post supervision system. While removing administrative approval to promote the development of the industry, they also give a play to the linkage mechanism between administrative filing and other innovative supervision methods, so as to form a regulatory mechanism with more precision and efficiency by combining the private regulatory advantages of multiple market players. However, due to the poor connection of supporting measures, the preset supervision mechanism has not played its due role as a substitute. In practice, the administrative licensing-style filing plays a major regulatory role. The tension between the institutional design and the regulatory reality stems from the localization difficulties faced in the process of transplanting and reconstructing the supervision system during and after the event in the Chinese context. The limited resources of education supervision and the path dependence of supervision methods, as well as the inherent insufficiency and weak stamina of private regulation in the online training market, all restrict the actual effectiveness of supervision during and after the event, resulting in a deviation between the purpose of supervision and the effect of reform. Therefore, the educational administrative organs try to reshape the in-process and ex-post supervision with ex-ante supervision, balance the tension between the logic of the market economy and other value goals in the process of regulation, and urge off-campus online training to return to the original intention of the “new education supply mode”.

Key words: off-campus online training, pre-supervision, in-process and post-supervisions, regulatory reform