How to ensure that China’s pension funds maintain and increase their values and give better play to the role of the market in the allocation of resources for pension funds? The key lies in the way pension funds investment changes from a positive list model to a negative list model. At present, the legislation affirms the positive list model. However, there are excessive government regulations in the conceptual level. In practice, social investment issues may arise, affecting the safety and efficiency of pension fund investments. Therefore, it is necessary to solve the concept and institutional problems arising from the investment of pension funds by establishing a negative list model for pension funds. The establishment of a negative list model for pension fund investment in China has both international experience and local practice in China, as well as theoretical support. The construction of this model is feasible. By establishing a negative list model for pension fund investment, the relationship between the government and the market can be clarified and the government’s social investment can be prevented; and the prevention of legal risks of the negative list model can be better promoted by clarifying the formulation subjects of the negative list, the applicable target, and the prevention of risks caused by the negative list.