What the app filing rules actually require
| Fact | Primary source |
|---|---|
| Section 2(1): an APP sponsor providing internet information services in mainland China must complete filing; without it, it may not engage in APP internet information services at all. | MIIT Notice 工信部信管〔2023〕105号, Section 2(1) |
| Section 2(9): network access providers, distribution platforms and smart terminal manufacturers may not provide access, distribution or pre-installation to an unfiled APP — which is why removal from a Chinese app store is the store meeting its own duty, not discretionary enforcement against you. | MIIT Notice 工信部信管〔2023〕105号, Section 2(9) |
| Section 2(5): the filing is submitted by your network access provider or distribution platform through the national filing system — an app sponsor cannot file independently of its hosting and distribution arrangement. | MIIT Notice 工信部信管〔2023〕105号, Section 2(5) |
| Section 2(7): where materials are complete and accurate, the provincial communications administration completes the filing within twenty working days. | MIIT Notice 工信部信管〔2023〕105号, Section 2(7) |
| Section 2(8): the filing number must appear in a prominent position inside the app with a link to the filing system beneath it; the distribution platform must display it too. | MIIT Notice 工信部信管〔2023〕105号, Section 2(8) |
| Section 3: the grace period for apps already live closed in March 2024; inspection ran April–June 2024 and the regime has been in normalised operation since July 2024. | MIIT Notice 工信部信管〔2023〕105号, Section 3 |
| MIIT issued the app record-filing notice in July 2023. It applied to new apps from 1 September 2023, with existing apps required to complete filing by 31 March 2024, after which MIIT began inspection. | Norton Rose Fulbright — New record filing requirements for internet application programs |
| The regime covers mini programs and quick apps as well as native apps, and applies across distribution channels including the China App Store, the Chinese Android stores, WeChat and Alipay — apps without a valid filing risk removal, and stores have acted on this. | Linklaters — China's new app filing regime |
| The filing is entity-based, as with websites: it is made in the name of a mainland China legal entity, so a company without an onshore vehicle cannot file directly. | Alibaba Cloud — ICP filing prerequisites |
| Delivery from inside mainland China — the only arrangement that removes the cross-border round trip — carries the regulatory gate with it: "ICP filing applies only to servers located in the Chinese mainland", and the filing binds to the access provider, not only the domain. | Alibaba Cloud — ICP filing prerequisites |
Sources verified by the 21YunBox compliance team on 2026-08-28.
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.
What the app filing notice actually says
The requirement is not a policy change announced by the app stores. It comes from a single MIIT notice, and the operative paragraphs are short enough to read.
Instrument: 《工业和信息化部关于开展移动互联网应用程序备案工作的通知》 — MIIT Notice on Carrying Out Mobile Internet Application Filing Work, 工信部信管〔2023〕105号, dated 21 July 2023. It is issued under the Anti-Telecom-and-Online-Fraud Law and State Council Decree No. 292, not as a standalone regime.
Filing is a precondition for operating the app at all
（一）在中华人民共和国境内从事互联网信息服务的APP主办者，应当依照《中华人民共和国反电信网络诈骗法》《互联网信息服务管理办法》（国务院令第292号）等规定履行备案手续，未履行备案手续的，不得从事APP互联网信息服务。
Section 2(1). An APP sponsor engaging in internet information services within the territory of the People’s Republic of China shall complete filing formalities in accordance with the Anti-Telecom-and-Online-Fraud Law, the Administrative Measures on Internet Information Services (State Council Decree No. 292) and other provisions. Without having completed filing formalities, it may not engage in APP internet information services.
And the app stores are the ones bound by it
（九）网络接入服务提供者、分发平台、智能终端生产企业不得为未履行备案手续的APP提供网络接入、分发、预置等服务。
Section 2(9). Network access service providers, distribution platforms and smart terminal manufacturers shall not provide network access, distribution or pre-installation services to an APP that has not completed filing formalities.
In practice: this is the paragraph that explains removals. The obligation binds the distribution platform, not only you — an app store that lists an unfiled app is itself out of compliance, so the removal is not discretionary enforcement against your product, it is the store meeting its own duty. It is the same structure as the website regime, where an access provider may not carry an unfiled site. If your app has disappeared from a Chinese store, this is usually why.
You cannot file directly — it goes through your access provider or store
（五）APP主办者应当向其住所所在地省级通信管理局履行备案手续，由其网络接入服务提供者、APP分发平台（以下简称分发平台）通过”国家互联网基础资源管理系统”……采取网上提交申请、查验审核方式进行。
Section 2(5). An APP sponsor shall complete filing formalities with the provincial communications administration of its place of domicile, carried out by its network access service provider or APP distribution platform through the National Internet Basic Resource Management System, by online submission and verification review.
In practice: the submission is made by your access provider or distribution platform, which is why the filing is bound to a specific hosting and distribution arrangement rather than to your company in the abstract. Section 2(6) puts a verification duty on them and forbids them from filing on your behalf when they know or should know the information is inaccurate.
The clock, and where the number goes
（七）省级通信管理局在收到APP主办者提交的备案材料后，材料齐全并准确的，应在二十个工作日内予以备案……
（八）APP主办者应当在APP显著位置标明其备案编号，并在备案编号下方按要求链接备案系统网址，供公众查询核对。分发平台应在显著位置标明其分发的APP备案编号信息……
Section 2(7). After receiving the materials, where they are complete and accurate, the provincial communications administration shall complete the filing within twenty working days … Section 2(8). The APP sponsor shall indicate its filing number in a prominent position in the APP, with a link beneath it to the filing system so the public can verify it. The distribution platform shall likewise display the filing numbers of the APPs it distributes …
In practice: twenty working days, measured from materials that are both complete and accurate — the notice adds accuracy to the completeness test that the website regime uses. And the display duty falls on the store as well as on you.
The dates that are now behind us
（二）存量APP备案阶段（2023年9月-2024年3月）……（三）监督检查阶段（2024年4月-2024年6月）……（四）常态化工作阶段（2024年7月至长期）。
Section 3. Existing-APP filing stage, September 2023 to March 2024 … supervision and inspection stage, April to June 2024 … normalised operation stage, from July 2024 onwards.
In practice: the grace period for apps that were already live closed in March 2024, and the regime has been in its normalised phase since July 2024. An unfiled app today is not early — it is late, and the distribution platforms have been under inspection obligations since April 2024.
Primary source: 《工业和信息化部关于开展移动互联网应用程序备案工作的通知》（工信部信管〔2023〕105号）, full text in the State Council policy database: gov.cn. Translations are ours and for orientation only; where the English and the Chinese differ, the Chinese governs. Not legal advice.
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.
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.
Secure Your App's ICP Filing
Need an ICP Filing Number for your app in China? Get expert guidance on how to comply with the latest regulations. Book a free consultation now.
Start NowKey Requirements for Obtaining an ICP Filing Number
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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.
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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.
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App Icon: Submit the most common app icons used across multiple platforms.
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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.
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App Type: Select the appropriate category from a list that includes options like domestic services, food, leisure & entertainment, travel, transportation, education, and more.
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App Details for Each Platform: Provide app details for each platform, including app package name, signature MD5 value, and platform public key.
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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:
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:
- Contact Apple through their official developer channel: https://developer.apple.com/contact/topic/SC1103/subtopic/30023/solution/select
- Explain your app’s offline nature and provide evidence.
- Supply screenshots and other information demonstrating offline functionality.
- 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
Legal Compliance and Market Access
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.
