Introduction to Mobile App ICP Filing in China

The recent regulatory changes for publishing mobile apps and games in Chinese app stores have brought about a significant shift. To help you navigate this new landscape, we’ve prepared a comprehensive guide to swiftly adapt to the revised regulations and understand their implications for your apps. If you’re also managing websites or e-commerce platforms in China, you might want to check our guides on obtaining an ICP license for websites and commercial ICP licenses as well.

New Regulations for App Submissions

For New App Submissions:

Starting from September 1, 2023, all new apps must undergo the ICP Filing process before they can be published on app stores in China. This rule applies to Apple App stores, as well as all Android app stores and mini-program app stores in China.

China Mainland ICP Filing Number - Apple
China Mainland ICP Filing Number - Apple
21YunBox Quote
An Internet Content Provider (ICP) Filing Number is an app registration number from China's Ministry of Industry and Information Technology (MIIT)

Apple App Store

Apple has already enforced this law by mandating a valid ICP Filing number for new app submissions in the China region by September 30, 2023. According to the official Apple Developer documentation on “Availability in China mainland”:

“China’s Ministry of Industry and Information Technology (MIIT) now requires all apps to possess a valid Internet Content Provider (ICP) Filing Number. Games must also obtain an approval number, and apps with books and magazine content or religious content must secure specific permits from the respective Chinese regulatory authorities. If your app falls into these categories and you plan to offer it on the App Store in China, you must provide the required information and supporting documents.”

This official statement from Apple underscores the critical nature of obtaining an ICP Filing Number for your app to operate in the Chinese market.

For Existing Apps:

Existing apps must provide a valid ICP Filing Number before March 31, 2024, or face removal from app stores in China. This gives app owners and companies a 10-month timeframe to obtain the necessary ICP Filing number and required licenses to operate in China.

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Key Requirements for Obtaining an ICP Filing Number

  1. Chinese Legal Business Entity: To operate an app or mini-program in China, you need a Chinese legal business entity that holds all the required licenses. International app developers must collaborate with a local partner, like 21YunBox, to publish and operate their apps in China.

  2. Domain Name Certificate (with China Real Name Verification)

  3. API or Web Services Domains: Provide details of the domains used in the app, including second-level, third-level, and fourth-level domain names, each already having a website ICP Filing Number.

  4. App Icon: Submit the most common app icons used across multiple platforms.

  5. Declaration of Restricted Category: If your app falls into specific categories such as news, publishing, education, healthcare, etc., provide proof that the Chinese legal entity holds the necessary licenses to operate in that category.

  6. App Type: Select the appropriate category from a list that includes options like domestic services, food, leisure & entertainment, travel, transportation, education, and more.

  7. App Details for Each Platform: Provide app details for each platform, including app package name, signature MD5 value, and platform public key.

  8. Basic Information of the Person in Charge of the App: Provide Chinese ID number, name, mobile number, office phone number, email, and WeChat ID (instant messaging in China).

Exceptions to ICP Filing: When Your App May Be Exempt

While most apps require an ICP filing under the new regulations, there are exceptions for truly offline apps. These are applications that have no internet connectivity and don’t store or load data to a database in any way, such as basic calculator apps or certain offline games.

The Internet Society of China has provided clarification on this matter in their FAQ:

Internet Society of China FAQ on ICP Filing Exceptions - Source: https://www.isc.org.cn/article/17570944022605824.html
Internet Society of China FAQ on ICP Filing Exceptions - Source: https://www.isc.org.cn/article/17570944022605824.html

As shown in the image, apps that don’t use network services are not required to obtain an ICP filing. However, it’s important to note that in today’s interconnected digital landscape, truly offline apps are becoming increasingly rare.

If you believe your app falls into this category, you’ll need to verify this status with Apple:

  1. Contact Apple through their official developer channel: https://developer.apple.com/contact/topic/SC1103/subtopic/30023/solution/select
  2. Explain your app’s offline nature and provide evidence.
  3. Supply screenshots and other information demonstrating offline functionality.
  4. Respond to any follow-up requests from Apple promptly.

It’s crucial to be accurate in your assessment, as misrepresenting your app can lead to rejection from the App Store and potential legal issues in China.

If you need assistance in communicating with Apple or navigating this process, our team at 21YunBox is here to help. We can guide you through the verification process or handle the communication on your behalf. Don’t hesitate to reach out for support in ensuring your app complies with Chinese regulations.

Where to Apply for the Mobile App ICP Filing Number

Submit your application to the filing system (available in Chinese) at http://beian.miit.gov.cn. We assist our customers throughout this process to ensure a smooth filing experience.

In case of incomplete or inaccurate materials, the provincial-level Communication Administration Bureau will reject the filing and notify the applicant accordingly.

Processing Time and Approval

After submitting the filing materials, the provincial-level Communication Administration Bureau typically completes the filing within twenty (20) working days. They will issue a filing number and notify the applicant via SMS or email. You can also check the status through the filing system website at http://beian.miit.gov.cn.

Displaying the ICP Filing Number in Your App

Once you obtain an ICP Filing Number, ensure it is clearly displayed within your app, for example in the “Settings” or “Introduction” screen. Make it easily visible and avoid hiding it or using inconspicuous colors.

The Importance of ICP Filing for Mobile Apps

Obtaining an ICP Filing Number is crucial for legally operating in China’s vast mobile app market. With over 1 billion smartphone users in China, securing proper licensing is essential for tapping into this enormous user base.

Avoiding Penalties and Removal

Operating without proper ICP filing can result in severe consequences, including:

  • Immediate removal from all Chinese app stores
  • Potential fines and legal action
  • Damage to your brand’s reputation in the Chinese market

As Apple’s documentation clearly states, apps without valid ICP Filing Numbers will not be allowed on the App Store in China. This applies to all other app stores in the country as well.

How We Can Assist You

We specialize in assisting businesses with applying for and securing their China compliance licenses, including mobile app ICP filings, website ICP licenses, and commercial ICP licenses. Our services include:

  • Guidance on document preparation
  • Assistance with navigating the application process
  • Support in meeting all legal requirements
  • Ongoing compliance monitoring and updates

If you need assistance and support in this process, reach out to us for a free consultation session.

Conclusion

Obtaining an ICP Filing Number for your mobile app is now a mandatory step for operating in the Chinese market. While the process can be complex, especially for international developers, the potential rewards of accessing China’s vast mobile user base make it a worthwhile endeavor.

Remember, the deadline for existing apps to comply is March 31, 2024. Don’t risk having your app removed from Chinese app stores – start your ICP filing process today.

For personalized assistance with your mobile app ICP filing or any other aspect of operating digital services in China, don’t hesitate to reach out to our team of experts at 21YunBox.

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