Abstract: The current “progressive” activation model of special representative litigation is justified and reasonable, but there are problems such as higher-order eligibility criteria for litigation, weakening of the parties’ procedural options, and deflated judicial review by the court, which hinder the normalization of the special representative litigation mechanism. The framework of a “two-tiered progressive approach” should be adhered to, with a focus on improving the second-tier initiation conditions for special representative litigation: in line with the provisions of the “Civil Procedure Law” and the “Securities Law”, the “selection of a qualified representative” is not one of the conditions for filing a lawsuit in ordinary representative litigation; Secondly, based on the functional orientation of special representative litigation to protect small and medium-sized investors and deter illegal activities, the conversion conditions should include a large number of parties, the procedural choices of the parties, the appropriateness of the litigation method, and the insurance institution’s diligent and responsible exercise of its powers. At the same time, the court’s procedural control should be at the center, with the judicial review procedure of the initiation conditions as the field, to ensure the correct application of the litigation process. The exercise of rights by the insurance institution should be limited to both statutory and contractual rights sources, lowering the standards for case selection and accepting investor supervision for refusing to participate in litigation.