How do you publish a mobile app in China?
Publishing a mobile app in mainland China is a compliance problem before it is a technical one. What decides whether your app can ship is a stack of permissions and data duties — not speed or reachability.
Every app needs its own mobile ICP filing (备案), issued to a mainland China legal entity; Chinese Android stores add a Software Copyright Certificate (软著) and their own content review, while the Provisions on Mobile Internet Application Program Information Services put real-name, content, data, and minors duties on both you and the store. The moment your app collects a mainland user's personal information, PIPL's notice, consent, and cross-border rules apply. And if your app is a game or carries other published or paid content, the sharpest gate is a separate online publishing license and a 版号 — which foreign capital cannot hold directly.
These are plain-English readings of Chinese regulations for quick comprehension, use at your own risk — treat each as a risk to confirm with counsel, not legal advice. Our China compliance team can map the ICP, app-store, and PIPL path for your app →
What actually decides whether your app can ship in mainland China
| Fact | Primary source |
|---|---|
| Every app needs its own mobile ICP filing (备案), issued to a mainland China legal entity. A website filing does not cover an app, and under the ICP record-filing regime no provider may serve, and no access provider may connect, an unfiled service inside mainland China. Under MIIT's app-filing program, new apps have had to file before launch and existing apps had to hold a valid filing number by March 31, 2024. The regime rests on State Council Order No. 292 and the ICP Filing Measures. | Measures for the Record-Filing of Non-Operational Internet Information Services (MII Order No. 33, as amended by MIIT Order No. 68, 2024) and Measures for the Administration of Internet Information Services (State Council Order No. 292), 21YunBox translation, retrieved 2026-10-08 |
| App distribution puts duties on both you and the app store. The Provisions on Mobile Internet Application Program Information Services (in force since August 1, 2022) require real-name verification, content review, data and personal-information protection, and safeguards for minors. Chinese Android stores additionally require a Software Copyright Certificate (软著) and their own content and qualification review before they will list an app. | Provisions on the Administration of Mobile Internet Application Program Information Services (CAC, effective Aug 1, 2022), 21YunBox translation, retrieved 2026-10-08 |
| Collecting a mainland user's personal information triggers PIPL. You must give notice and obtain consent, and sending that data offshore is a cross-border transfer governed by PIPL Articles 38–40 — requiring a lawful transfer mechanism (a CAC security assessment, the CAC standard contract, or certification), with data-localization pressure that scales with your role and the volume of data you handle. | Personal Information Protection Law (PIPL), Articles 38–40, 21YunBox translation, retrieved 2026-10-08 |
| Games and other published or paid content face the sharpest gate. Online games need a publishing approval number (版号, issued as an ISBN) from the National Press and Publication Administration (NPPA), and fall under the Provisions on the Administration of Online Publishing Services — which bar foreign-invested companies from holding an online publishing license (Article 10) and require the serving infrastructure to be inside mainland China (Article 8). In practice you publish through a licensed Chinese publisher of record. | Provisions on the Administration of Online Publishing Services (SAPPRFT & MIIT Order No. 5, Articles 8 and 10), 21YunBox translation, retrieved 2026-10-08 |
Sources verified by the 21YunBox compliance team on 2026-10-08.
Publishing a mobile app in mainland China is a compliance problem before it is a technical one. Four gates decide whether — and how — your app can ship, and none of them is about speed:
- a mobile ICP filing (备案) for the app and the backend it talks to inside the mainland, issued to a mainland China legal entity;
- app-store review under the Provisions on Mobile Internet Application Program Information Services — real-name, content, data, and minors duties that fall on both you and the store, plus a Software Copyright Certificate (软著) for Chinese Android stores;
- PIPL obligations the moment your app collects a mainland user’s personal information; and
- for games or other published or paid content, a separate online publishing license and a 版号 — the sharpest gate of all, and one foreign capital cannot hold directly.
Everything below is our plain-English reading of Chinese regulations, offered for quick comprehension and use at your own risk — treat each point as a risk to confirm with counsel, not as legal advice. With that framing, here is the sequence a China app launch actually runs in.
Understanding Your Options
App owners in the West have two primary options for distributing apps and games in China:
Option A: Local Distribution Service Provider
When considering how to publish your app in China, Option A is often the quickest and most reliable route. By partnering with a local distribution service provider, you gain valuable support throughout the approval process, ensuring a smoother experience. They can handle queries and guide you through the necessary steps.
Option B: Self-distribution
While self-distribution is possible, it’s a slower process and requires more documentation. It’s important to note that you’ll need to have a Chinese company or entity for this option to be viable.
Not sure which licenses your app needs?
Our China compliance team will map the ICP filing, app-store, and PIPL requirements for your app — and show how 21YunBox delivers your backend compliantly from inside mainland China.
Get a compliance assessmentEssential Requirements
Before you submit your app to a Chinese app store, ensure you have the following essential requirements in place:
1. A Chinese Company, Entity, or Distributor (Android only)
Foreign companies cannot directly publish their apps on Chinese Android app stores. You must have a Chinese entity or use an authorized local distributor. Having an office in China is not enough.
2. Localized App APK
For your app to succeed in China, it must meet Chinese norms. This means translating all text to Simplified Chinese and ensuring that user-generated data is hosted on servers inside mainland China. Additionally, it should not rely on cloud services, APIs, or SDKs that are inaccessible from inside mainland China.
3. Localized App Name, Description, and App Icon
Choosing your app’s name carefully is crucial since it may need to match your SCC registration. Craft a compelling app description, which plays a vital role in App Store Optimization (ASO). If you need professional assistance with localization, services like 21YunBox can help.
4. User’s Manual For Your App
Government regulators will review your app. However, they won’t test it themselves. Instead, they’ll rely on a user’s manual provided by you. This manual should comprehensively explain how your app functions, including screenshots and examples.
5. Chinese Software Copyright Certificate (SCC)
To publish your app on major app stores in China, you’ll need a Chinese Software Copyright Certificate (SCC, 软著). This certificate, with a unique serial number, is essential for IP protection and app publication. The SCC application process typically takes about a month.
Link: How To Obtain a SCC Filing Number in China
6. 80 Pages of Source Code
Part of the SCC registration process requires you to submit a chunk of your app or game’s code to protect your intellectual property. The government agency with your SCC will hold this code as evidence in case you ever need to claim someone else violated your software’s copyright. You can choose which part of your code to submit.
7. Additional Documentation and Compliance
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Depending on your app’s type (e.g., travel, finance, health), industry-specific documentation may be required for distribution.
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App providers and app stores share duties under the Provisions on the Administration of Mobile Internet Application Program Information Services (in effect since August 1, 2022): real-name verification, content review, data and personal-information protection, and safeguards for minors. Chinese Android stores also typically require their own content and qualification review before they will list your app.
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Since 2019, app developers and publishers must complete a Security Assessment Form to publish or update apps on their platforms.
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With the Personal Information Protection Law (PIPL) in effect since November 1, 2021, every app must inventory the personal information it collects, give clear notice, and obtain the consent PIPL requires — all documented in its user privacy policy. Link: Personal Information Protection Law of the People’s Republic of China
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Cross-border data transfer: personal information collected in mainland China should be stored on infrastructure inside the mainland, and sending it offshore is a cross-border transfer governed by PIPL Articles 38–40. That requires a lawful transfer mechanism — a CAC security assessment, the CAC standard contract, or certification — with thresholds that turn on your role and the volume of data you handle.
Hosting Solutions and Compliance
Your app’s backend and landing pages still have to be served from inside mainland China under a valid ICP filing — and many apps depend on third-party cloud services, APIs, or SDKs that are unreachable from the mainland. 21YunBox sits on top of your existing stack as a compliant delivery and ICP overlay: we serve your app’s backend and site from inside mainland China under an ICP filing, keep the third-party services your app relies on working, and do it without rebuilding or migrating your application.
See how to make your app or game compliant with Chinese law and our delivery solutions for Google-based stacks.
Legal compliance is crucial for a successful online presence in China. 21YunBox provides a compliance assessment to help ensure your app meets the necessary requirements before publishing.
Game License (for Games)
If your app is a game — or carries other published or paid content — the gate is sharper. Online games need a publishing approval number (版号, issued as an ISBN) from the National Press and Publication Administration (NPPA), granted only once the game is approved. Games also fall under the Provisions on the Administration of Online Publishing Services, which bar foreign-invested companies from holding an online publishing license (Article 10) and require the serving infrastructure to sit inside mainland China (Article 8). In practice, that means you publish through a licensed Chinese publisher of record.
Link: How To Publish Your Game In China
Mobile App ICP Filing Number
Every app distributed in mainland China needs its own mobile ICP filing (备案) — a separate filing from any website ICP, made per app and issued to a mainland China legal entity. Under MIIT’s app-filing program, new apps have had to file before launch and existing apps had to hold a valid ICP Filing Number by March 31, 2024 to avoid removal from app stores; regulators and stores have enforced this by inspection since. The filing regime sits on State Council Order No. 292 and the ICP Filing Measures (MII Order No. 33, as amended by MIIT Order No. 68).
Link: How To Obtain a Mobile App ICP Filing Number in China
Self-Publishing Requirements
If you are self-publishing, you’ll need the following additional items:
- Power of Attorney Letter
- Chinese Business Registration
- Photocopy of Passport (Business registration holder)
- Chinese SIM Card
- Signed Individual App Store Development Statement/Claim Guarantee Letter
Link: How To Publish Your Game In China
Submission and Review Process
Once you have all the necessary materials, you’ll need to submit them along with your app or game’s APK to each app store individually. There is no “blanket submission form” that covers all stores.
Approval Timeline
The approval process commonly takes one to three months for standard apps and often six to twelve months for games — treat these as typical ranges that vary by category, store, and the completeness of your documentation. It’s advisable to start the process as early as possible.
This timeline is crucial for planning, especially if you’re launching a game. Games often require more time, and understanding these timelines can help you better strategize your release.
From here, you can upload your app’s APK file individually to each app store you wish to publish on, along with the supporting documentation you’ve gathered through this process. Keep in mind that each app store will have its unique interface and requirements for submission. Most will not provide an English-language interface, emphasizing the importance of seeking support, especially for ongoing maintenance.
How We Can Help
21YunBox helps international teams ship apps and games in mainland China on two fronts. We map the compliance path — the mobile ICP filing, the app-store steps (including the Software Copyright Certificate), PIPL and cross-border data obligations, and, for games, the online publishing license and 版号 route — so you know the sequence before you commit to it. And we deliver it: your app’s backend and landing pages served from inside mainland China under an ICP filing, with the third-party services your app depends on kept working, no rebuild or migration required. You’ll have one-on-one contact with a dedicated account manager and access to our online client dashboard.
Making your app’s presence in China a reality is possible — with the gates mapped and the delivery handled on compliant, in-country infrastructure.
Ready to map your app's path into China?
Share your stack and target stores. We'll return the compliance sequence for your specific app and the in-country, ICP-filed delivery plan to run it — no rebuild or migration required.
Talk to our China compliance teamThese steps are a starting map, not legal advice — your exact obligations turn on your app, your data, and your corporate structure, so confirm them with counsel before you build toward a date.