Does Fastly Work in China? ICP Filing & In-Country Delivery
Fastly reaches mainland China from offshore; genuine in-country delivery needs an ICP filing and a separate licensed China arrangement. A compliance-first look at the two doors.
Does Fastly work in China?
Whether you can run Fastly for mainland China is a licensing-and-location question, not a speed one. Fastly is reachable from inside China — the catch is where it delivers from, and what genuine in-country delivery would require of you.
By Fastly's own account its closest point of presence is in Hong Kong; it has none inside mainland China and reaches Chinese users from its global rim, not from on the ground. Fastly is explicit that putting delivery nodes physically on the ground in China means a local affiliate and a separate contract you sign yourself. That on-the-ground step is the one China regulates: any site served to the public from inside the territory needs an ICP filing (State Council Decree 292; MIIT Decree 33), and operating delivery nodes there is a licensed activity requiring a China entity. The table below is Fastly's own wording and the filing rule it runs into.
This is a risk-and-architecture picture, not a verdict — what you need turns on your domains, traffic and content. Our China team can map the two doors — filing and in-country delivery — with you →
Compliance snapshot
- ✓ Not blocked — Fastly is reachable from mainland China
- ! Delivered from offshore rim POPs; Fastly's closest is Hong Kong
- ! True in-country delivery needs a separate China affiliate contract
- ✕ No mainland POP — no ICP-filed in-country delivery through Fastly alone
- ✓ A compliant path exists: ICP filing + licensed in-country delivery
What Fastly's documentation says, and what we measured from inside China
| Fact | Primary source |
|---|---|
| In Fastly's own words: "Fastly's closest POP, for example, is in Hong Kong." Fastly operates no point of presence inside mainland China; its published network map lists Asia POPs such as Hong Kong, Seoul, Tokyo, Osaka and Singapore, but none on the mainland. Fastly reaches Chinese users from this offshore rim, "without affiliate peering." | Fastly — 'Global CDNs in China: What You Need to Know About Performance' (solutions brief, 2024) and Fastly Network Map, retrieved 2026-10-07 |
| Fastly states that genuine on-the-ground delivery in China comes from "a local affiliate in China" whose POPs are "physically on the ground," and that relying on that affiliate "inevitably results in you signing a separate contract with the affiliate directly – there is no global CDN who can independently handle delivery end-to-end for you including China." In-country delivery is therefore a step Fastly hands to you, not one it performs. | Fastly — 'Global CDNs in China: What You Need to Know About Performance' (solutions brief, 2024), retrieved 2026-10-07 |
| Serving from inside the territory is the trigger. Any website served to the public from inside mainland China must carry an ICP filing: State Council Decree No. 292 (Administrative Measures on Internet Information Services) establishes that a filing is required, and MIIT Decree No. 33 (in force since 20 March 2005), Article 5, attaches that obligation to serving from inside the territory. The moment a CDN terminates traffic on POPs inside China — the only way to get true in-country delivery — that filing is in scope, and running the nodes is a licensed telecom activity needing a China entity. | State Council Decree No. 292; MIIT (then MII) Decree No. 33, Article 5 — State Council Gazette 2005 No. 32, retrieved 2026-10-07 |
| Measured 2026-08-28 from a probe inside mainland China (Alibaba Cloud cn-zhangjiakou), Fastly loaded fully 1 time out of 3, first byte in a median 1,141ms. | 21YunBox — 280-site China delivery census, measured from inside mainland China |
| An ICP filing is necessary but not sufficient: when 21YunBox measured four delivery arrangements from a mainland probe, the in-country, filed, but unoptimized path still failed to finish loading. Permission (the filing) and reachability (in-country delivery that actually completes) have to be designed together — buying one without the other leaves you short. | 21YunBox — 'Four ways to deliver a website into China, measured' (2026-08-28), measured from inside mainland China |
Sources verified by the 21YunBox compliance team on 2026-10-07.
Whether Fastly “works” for mainland China is a licensing-and-location question before it is a performance one. Fastly is reachable from inside China — but by its own account it delivers from offshore: its closest point of presence is Hong Kong, and it operates none inside the mainland. The genuine, on-the-ground delivery that China actually regulates is a step Fastly hands to you — a local affiliate, a separate contract you sign yourself, and the filing that any site served from inside the territory requires. Those are the two doors: an ICP filing and licensed in-country delivery. Fastly describes both in its own words.
Fastly China at a glance
| What decides it | In Fastly's own terms |
|---|---|
| Where it delivers from | Closest point of presence is Hong Kong; none inside mainland China. Chinese users are reached from Fastly's offshore rim, “without affiliate peering.” |
| On-the-ground delivery | Comes from “a local affiliate in China” whose POPs are “physically on the ground” — not from Fastly's own network. |
| Who contracts it | Relying on that affiliate “inevitably results in you signing a separate contract with the affiliate directly.” |
| Serving the public from inside | A site served from inside the territory needs an ICP filing (State Council Decree No. 292; MIIT Decree No. 33), and operating in-country nodes is a licensed activity requiring a China entity. |
Door one — serving from inside China turns on an ICP filing
Because Fastly delivers from Hong Kong today, using it does not, by itself, create a filing obligation — the offshore rim sits outside the territory the rule reaches. But the moment delivery terminates on points of presence inside the mainland — the only way to get true in-country delivery — an ICP filing is in scope. State Council Decree No. 292 (Administrative Measures on Internet Information Services) establishes that the filing is required; MIIT Decree No. 33, Article 5 — in force since 20 March 2005 — attaches that obligation to serving from inside the territory. So the filing is not a formality bolted on at the end: it is the permission that licensed in-country delivery turns on.
Door two — in-country delivery is a separate, licensed arrangement Fastly hands off
Fastly is equally explicit that closing the in-country gap is not something it performs for you. Genuine on-the-ground delivery comes from a local affiliate whose nodes sit “physically on the ground” in China, and — in Fastly’s words — “there is no global CDN who can independently handle delivery end-to-end for you including China.” Leaning on that affiliate “inevitably results in you signing a separate contract with the affiliate directly.” Operating those in-country nodes is itself a licensed telecom activity that requires a China entity. In other words, in-country delivery is a door Fastly points you toward: the affiliate relationship, the contract and the license are yours to arrange, layered on top of the filing in door one.
This is a risk-and-architecture map, not a verdict. Which doors you need — and in what order — turns on your domains, your traffic and the data your site handles. If your Fastly setup also fronts logins, forms or APIs that carry personal information, a cross-border personal-information layer under PIPL can apply on top of the filing and delivery questions. These are calls worth settling with counsel before you localize, not a blanket yes or no.
Where 21YunBox fits — a compliant overlay, not a migration
You keep running Fastly. We add the one step Fastly hands off: compliant, ICP-filed, licensed in-country delivery, placed in front of your existing origin — no rebuild, no second codebase, and no move off Fastly. Our China team maps which doors your setup needs, handles the filing, and stands up in-country delivery that is both permitted and reliable. It has to be both: when 21YunBox measured four delivery arrangements from a probe inside the mainland on 2026-08-28, the in-country, filed-but-unoptimized path still failed to finish loading — permission and reliable delivery have to be designed together, which is exactly what the overlay does.
Related reading:
Frequently Asked Questions
Does Fastly have servers or POPs inside mainland China?
No. By Fastly's own account its closest point of presence is in Hong Kong, and its network map lists no mainland-China location. Fastly reaches Chinese users from its offshore rim network, not from inside the Great Firewall.
Is it against the law to use Fastly for a site seen in China?
Not in itself. Because Fastly delivers from outside the mainland, using it does not by itself create an ICP filing obligation — but it also cannot give you compliant in-country delivery. The filing rule (State Council Decree 292; MIIT Decree 33) attaches the moment content is served from inside the territory — the on-the-ground step Fastly leaves to a separate local-affiliate contract. And if your Fastly setup also fronts logins, forms or other requests carrying personal data, a cross-border personal-information layer can apply on top. Treat it as an architecture-and-licensing question to settle before you localize, not a blanket prohibition.
Can 21YunBox help run Fastly, or a Fastly-fronted site, compliantly in China?
Yes. Our China team can work through both doors with you — the ICP filing your domain needs to be served from inside the mainland, and licensed, in-country delivery that measurably completes — so the on-the-ground step Fastly hands off does not land on you unmanaged. Get in touch to map your specific setup.
