Abstract: Complex policy theory was adopted to find the logic of elderly sports policy network analysis, including its discrepancy, network form and the dominant roles of major participants. Based on the method of policy network analysis, the research was conducted on the 150 elderly sports policies of Shanghai for the intergovernmental relations, dominant roles of network participants and overall network patterns. The conclusions are as follows: The interaction of the government on municipality levels and district levels, as well as each municipal department, functions importantly on the aspects of agenda setting and resource allocation of elderly sports policies; The interaction between district government and sub-district government plays a critical role in coordinating and complementing elderly sports policies; Comprehensive elderly sports policies will lead to the interaction between the functional departments on municipal levels and district levels, hence to form the horizontal resource integration; Special elderly sports policies will lead to the interaction between the governments on district levels and sub-district levels, promoting the special resources directly to the bottom levels. Suggestions are proposed to integrate resource and optimize the right and responsibility to break barriers, and to locate the value of policy accurately through balancing the nature of guarantee and welfare.