In November 2022, the Cyberspace Administration of China (CAC) issued the revised “Regulations on the Management of Internet Comment Services.” Effective from December 15, 2022, these new regulations aim to strengthen the standardized management of internet comment services, safeguard national security and public interests, protect the legitimate rights and interests of individuals, legal entities, and other organizations, and promote the healthy development of internet comment services. The updated regulations emphasize the responsibilities of comment service providers, requirements for comment service users, and obligations for public account operators.

Strengthening Responsibilities of Comment Service Provider

One crucial requirement stands out among the numerous updates: forums, social media platforms, and other content-sharing platforms are now required to strictly enforce real-name registration for posting and commenting users.

According to Artcicle 4 of the Regulations, “Comment service providers shall strictly implement the main responsibility for comment service management and fulfill the following obligations in accordance with the law, based on the principle of “real-name authentication in the backend, voluntary choice in the frontend,” authenticate the real identity information of registered users through mobile phone numbers, identification card numbers, or unified social credit codes. They must not provide comment services to users with unverified or fake identity information or users who impersonate organizational institutions or other individuals.

Artcicle 4: real-name authentication in the backend, voluntary choice in the frontend.
Artcicle 4: real-name authentication in the backend, voluntary choice in the frontend.

Under the revised regulations, comment service providers are assigned greater responsibilities. They are expected to implement measures to verify the real identities of users and ensure compliance with content guidelines. Companies intending to operate in China should prioritize establishing robust mechanisms for user identification and content moderation to align with the requirements.

The new regulations also necessitate real-name registration for users engaging in posting and commenting activities on various platforms. This measure enhances accountability and helps to deter the spread of false information or malicious content. Western companies entering China’s market should acquaint themselves with these requirements and adapt their platforms and services accordingly to accommodate real-name registration.

Which platforms are affected by this regulation? According to it, “Internet comment services referred to in these regulations mean internet websites, applications, and other website platforms with the attributes of public opinion or social mobilization, which provide services for users to post text, symbols, expressions, images, audio, video, and other information through commenting, replying, leaving messages, bullet screens, liking, and other methods.”

As for public account operators, including media outlets, online influencers, and bloggers, are also subject to specific obligations under the updated regulations. They are expected to exercise due diligence in managing and verifying the identities of their followers and commenters. Foreign companies seeking to establish public accounts or collaborate with local influencers should be mindful of these obligations and ensure compliance.

Implications for Western Companies

China’s new regulations on internet comment services pose important considerations for western companies venturing into the Chinese market:


To operate in China, companies must familiarize themselves with and adhere to the regulations outlined by the CAC. This involves implementing mechanisms for real-name registration, content moderation, and user verification to ensure compliance with the guidelines.

Market Entry Strategy

Western companies should carefully evaluate the impact of the new regulations on their market entry strategy. Understanding the requirements and adjusting their platforms and services accordingly will facilitate smoother operations and help establish trust among Chinese users.

Privacy and Data Protection

Given the real-name registration requirement, companies should pay close attention to privacy and data protection measures. Implementing robust safeguards and abiding by China’s data protection laws will be essential for maintaining user trust and complying with local regulations.

Collaboration and Partnerships

Establishing collaborations with local partners who have experience navigating the Chinese regulatory landscape can be advantageous. Partnering with established Chinese platforms or leveraging local expertise can help companies overcome regulatory challenges more effectively.

Chinese collaborations with ease

If you’re looking to expand your business to China or improve your online forms’ accessibility in the country, we’re here to help. Our team specializes in navigating the complexities of China’s internet landscape and can provide tailored solutions to ensure your online forms are functional and effective. Contact us today to learn more about our services and how we can help your business succeed in China.

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