Your customer needs mainland China. Here is what they are actually up against.
This page exists for account executives, solution architects and implementation partners
who have just heard “and it has to work in China” and need a straight answer
before the next call. It is written to be forwarded: no pitch, and every regulatory claim
traceable to a primary source.
The short version
There are two independent gates. Performance: the
origin sits outside the mainland, so every request crosses a congested, filtered
border — and Hong Kong or Singapore edges are on the far side of it, so they move the
crossing rather than remove it. The filing: anything actually served
from inside mainland China needs a valid ICP filing, issued to a mainland legal entity
and bound to whoever serves the traffic. The two interact —
the fast path and the filed path are the same path, because
in-country delivery is what removes the border crossing and also what triggers the
filing. So every arrangement that avoids the filing is one that keeps the latency.
The four options, on both gates
| Option | Fixes performance | Needs an ICP filing | Impact on your build |
| Do nothing, tune what you can | No | No | None |
| Near-shore CDN (Hong Kong / Singapore) | Static assets only — APIs and forms still cross | No, because it never enters China | None |
| Rebuild a separate site inside China | Yes | Yes — the customer holds it | A second codebase and content workflow, permanently |
| China delivery layer over the existing build | Yes | Yes — attaches to the delivery layer | None — your build stays the origin and source of truth |
The near-shore option is the one most teams try first and the one that disappoints most
reliably. The rebuild genuinely works and is genuinely expensive — not in infrastructure
but in operations.
What this does to your delivery schedule
The engineering is the short part. The schedule is set by the filing, which runs in weeks
and cannot be compressed by paying more. Three things routinely land late:
- The domain comes first. A domain registered outside mainland China has
to be transferred to a MIIT-approved mainland registrar before it can be filed at all.
On real projects the slow part is finding who inside the customer’s organisation
controls the registrar account.
- An existing filing is not automatically valid for a new build. The
filing binds to the access provider, so a replatform means updating it — and a filing
with no current provider can be cancelled outright.
- No mainland entity means no filing. If the customer has none, this is
a corporate-structure decision rather than a technical one, and it needs to start
early.
Per-platform detail
Each of these sets out the mechanism for that platform specifically, cited to the
vendor’s own documentation rather than to us.
Also useful: which CDNs actually have mainland nodes, and who holds the ICP,
and the ICP filing in full.
Questions we get from account teams
My customer asks whether their site will work in mainland China. What is the short answer?
It will load, unreliably, and the dynamic parts will not. Their origin is outside the mainland, so every request crosses a congested and filtered border — the symptom is inconsistency rather than uniform slowness. Separately, the third-party services on the page (fonts, consent, analytics, video, marketing-automation forms) fail on their own schedule, so a page can render and still convert nothing.
Can we just add a China CDN and be done?
Only if its points of presence are actually inside mainland China, and only if someone holds a valid ICP filing. Most international CDNs with mainland nodes operate bring-your-own-licence: the infrastructure is theirs, the filing is the customer’s problem. And the filing requirement follows delivery, not just hosting — it applies whether the site sits on a mainland server or is merely delivered into China through a CDN.
What is the ICP filing and why does it keep appearing in the schedule?
It is the registration that makes serving from inside mainland China lawful. Three properties surprise most teams: it is triggered by where the server is, not by who owns the site; it is issued to a mainland China legal entity, so a foreign company cannot hold one directly; and it binds to the hosting/access provider, so changing where delivery happens means updating the filing. It runs in weeks and cannot be bought faster, which is why it — not the engineering — usually sets the go-live date.
Our customer has no Chinese entity. Is that a blocker?
For a direct filing, yes. The two routes are to incorporate onshore — months, registered capital, ongoing obligations — or to work with a partner that holds the filing and stands as the entity of record while the customer keeps their platform, content and IP. The second is not a cheaper version of the first; it is a different arrangement in which someone else carries the compliance liability.
Does the customer have to rebuild their site for China?
No, and the rebuild is usually the expensive answer. It works, but the cost is operational rather than infrastructural: a second codebase, a second content workflow, and a marketing team publishing twice. A delivery layer over the existing build keeps the global platform as the single source of truth.
What do you need from us to scope this?
The platform and where the head is hosted, every domain and gated area in scope, whether an ICP filing already exists and in whose name, and the go-live date. Those four answers are usually enough for a budgetary range. Environment count and traffic refine it.
How early should China enter an RFP response?
At the costing stage, even when delivery is a later phase. China is frequently a non-negotiable requirement that arrives last in the conversation, and a response that cannot forecast it loses on predictability rather than on price. Getting a budgetary number into the forecast early is usually worth more than getting the architecture exactly right.
Working an active opportunity
We run technical walkthroughs for account teams and their customers, and we will produce a
budgetary range for an RFP response from the four answers listed above. We work through
the partner and do not go around them: the customer relationship stays yours.
Talk to our China engineering team
