What is China’s B23 License and Who Needs One?

Businesses providing store-and-forward messaging services in China, including email systems, voicemail platforms, or fax storage and forwarding solutions, are legally required to obtain a B23 License, also known as the Store-and-Forward Services License or 增值电信业务经营许可证-存储转发类业务 in Chinese. This comprehensive guide covers everything you need to know about the B23 License: its legal foundation, who needs it, the application process, and how to stay compliant with Chinese regulations.

What is the B23 (Store-and-Forward Services) License?

The B23 License, formally known as the “Store-and-Forward Services Business License” (存储转发类业务许可证) is a commercial operating license required for businesses that utilize store-and-forward mechanisms to provide message sending services in Mainland China. The B23 License is specifically designed for companies that offer email, voicemail, fax storage and forwarding, or other asynchronous messaging services where messages are stored temporarily before being delivered to recipients.

The B23 designation refers to the specific category within the Ministry of Industry and Information Technology’s (MIIT) telecommunications business classification system, where “B23” represents “Store-and-Forward Services Business” (存储转发类业务). This is classified as a Second-Class Value-Added Telecommunications Service.

This license serves as the government’s primary mechanism for regulating store-and-forward messaging platforms, ensuring that businesses providing these services in China comply with local laws and maintain service quality and security standards.

What is the Legal Foundation of the B23 License?

As part of the Value-Added Telecommunications Services (VATS) or 增值电信业务, the Telecommunications Regulations of the People’s Republic of China (中华人民共和国电信条例) applies to the B23 License.

Article 7 of the Telecommunications Regulations establishes that all telecommunications businesses require a license:

“The State shall implement a licensing system for telecommunications businesses in accordance with the classification of telecommunications businesses. Telecom operators shall apply to the information technology administration department of the State Council or the telecommunications administration authorities of the province, autonomous region or centrally-administered municipality for a telecommunications business permit pursuant to the provisions of these Regulations. No organisation or individual shall engage in telecommunications business without obtaining a telecommunications business permit.”

Article 8 clearly states that there are two types of telecommunications businesses: basic telecommunications and value-added telecommunications.

“Telecommunications businesses are categorised into basic telecommunications businesses and value-added telecommunications businesses. Basic telecommunications businesses shall mean the businesses of providing public network infrastructure, public data transmission and basic voice communication services. Value-added telecommunications businesses shall mean making use of public network infrastructure to provide telecommunications and information services.”

Who Needs a B23 (Store-and-Forward Services) License?

The B23 License is required when providing store-and-forward services that utilize storage and forwarding mechanisms for message delivery between users. According to MIIT’s Classification Catalogue of Telecommunication Services (2015), Store-and-Forward Services refer to:

“the message sending services provided for users by utilizing the store-and-forward mechanism. Store-and-forward services include the voice mail, e-mail, fax store-and-forward, etc.”

This therefore means that you will need a B23 License if your business revolves around any of the following:

Types of Store-and-Forward Services:

• Voice Mail Services (语音信箱服务业务) – Voice mail services refer to the storage, extraction, and use of voice messages and other auxiliary functions provided for users by utilizing a voice mail system connected with public communication networks, public data transmission networks, or the Internet. Each voice mail has a special mail number, and users may deliver, receive, store, delete, forward voice messages, or receive notifications through telephone, computer, or other terminal equipment. Common applications include corporate voicemail systems, personal voicemail services, visual voicemail platforms, and unified messaging systems.
• E-mail Services (电子邮件服务业务) – E-mail services refer to services of one-to-one or one-to-many e-mail editing, sending, transmission, storage, forwarding, and receipt provided for users by adopting various kinds of e-mail transmission protocols through the Internet. Users are provided with various types of information exchange in a store-and-forward manner by combining intelligent terminals, computers, and other devices with public communication networks. Common applications include enterprise email hosting platforms, consumer email services, email gateway and relay services, mailing list distribution, email archiving systems, webmail interfaces, and email security services.
• Fax Store-and-Forward Services (传真存储转发服务业务) – Fax store-and-forward services refer to the non-real-time sending of faxes at the other end, with such faxes being controlled by the store-and-forward system set up between fax machines and between fax machines and computers. The system is composed of fax workstations and fax store-and-forward mailboxes connected through packet networks, digital private lines, or the Internet. Service features include multi-site delivery, scheduled delivery, fax mail, designated receiver communication, message filing, and archiving. Common applications include internet fax services, fax-to-email conversion, and cloud-based fax platforms.

The B23 License applies specifically to store-and-forward services where messages are stored temporarily before delivery. Real-time communication services like instant messaging typically require different licenses such as the B25 ICP License.

This means any application, game, or device in China that provides voicemail, email, or fax functionality between two or more users using store-and-forward mechanisms will require a B23 License.

What are the Basic Requirements to Apply for the B23 License?

Obtaining a B23 License requires meeting specific ownership, operational, and infrastructure requirements set by MIIT.

Ownership Structure

Foreign ownership limits vary by region:

Pilot Regions: According to the Ministry of Industry and Information Technology’s Notice on Launching Pilot Work for Expanding Opening Up of Value-Added Telecommunications Services (工业和信息化部关于开展增值电信业务扩大对外开放试点工作的通告), as of April 8, 2024 Beijing, Shanghai, Hainan, and Shenzhen have eliminated foreign capital restrictions for certain VATS businesses. Store-and-forward services (B23) are included in the pilot program liberalization. In these four pilot regions, WFOEs (Wholly Foreign-Owned Enterprises) can apply for VATS Licenses, including the B23 License.

It is important to note, while legally permissible, obtaining a VATS license as a WFOE in pilot regions remains exceptionally difficult in practice. Approval thresholds are extremely high, with authorities primarily approving well-known multinational enterprises. As of 2025, only 13 companies total have successfully obtained VATS licenses as WFOEs across all categories since the pilot program began.

Other Regions: Outside of pilot zones, foreign-invested enterprises may face restrictions. According to the Administrative Measures for Foreign-Invested Telecommunications Enterprises (外商投资电信企业管理规定), it is recommended to consult with local Communications Administrations regarding current foreign investment policies for B23 licenses, or collaborate with a Chinese partner such as AppInChina.

Domestic companies face no ownership restrictions and can operate with 100% Chinese ownership nationwide.

Company Requirements

• Your company must be legally established under Chinese law with “Value-Added Telecommunications Business” (增值电信服务) or “Telecommunications Business” (电信业务) explicitly listed in your business scope.
• You need minimum registered capital of CNY 1 million for provincial operations or CNY 10 million for cross-provincial operations (nationwide operations).
• The company and its key personnel must have clean records with no telecommunications violations in the past three years and cannot be included in the list of dishonest telecommunications business operators.

Technical Infrastructure

• Store-and-forward system infrastructure must demonstrate capability for message storage, management, and delivery with appropriate reliability and redundancy measures.
• Network architecture must demonstrate capability for handling email, voicemail, or fax traffic with appropriate storage capacity, bandwidth, and delivery mechanisms.
• Technical plans must demonstrate platform functionality, message storage and forwarding mechanisms, service quality assurance, and service level agreements.
• Equipment requirements include mail servers, storage systems, network equipment, and backup infrastructure necessary to provide reliable store-and-forward services. Equipment must meet national standards for telecommunications services.
• A cybersecurity department with supporting internal regulations is mandatory, including network security monitoring, incident response procedures, and data protection measures for stored messages.

Companies must ensure compliance with data localization regulations and implement robust security controls for user messages and data during storage and transmission.

Personnel Requirements

• You need at least 3 Chinese employees with social security (社保) records covering recent months from your company for the application materials.
• Technical staff with relevant qualifications in email systems, messaging infrastructure, network engineering, and cybersecurity are required. Staff should have backgrounds in computer science, network engineering, or related fields.
• Management personnel with relevant experience in telecommunications or messaging services are also required.

Foreign Enterprise Requirements

Foreign-invested enterprises face additional requirements:

For pilot regions (Beijing, Shanghai, Hainan, Shenzhen): Foreign enterprises including WFOEs can apply for the B23 License, with the great level of difficulty detailed above, and must submit applications to the Ministry of Industry and Information Technology (MIIT) rather than provincial authorities.

For all foreign-invested enterprises, regardless of region:

Your legal representative may need to be a Chinese national or permanent resident (requirements vary by region).

You must demonstrate store-and-forward services operational experience through system architecture diagrams, service documentation, technical specifications, and case studies.

Additional documentation required for foreign enterprises:

• Foreign Investment Security Review Decision (《外商投资安全审查决定书》) if applicable
• Foreign shareholder overseas registration certificates with notarization and authentication
• Articles of association showing foreign investment structure
• Proof of foreign investor’s financial stability and business qualifications

Businesses registered in Hong Kong, Macau, or free-trade zones may enjoy additional advantages and have additional application requirements.

How to Apply for the B23 (Store-and-Forward Services) License

The B23 License application process is administered through regional telecommunications authorities under MIIT oversight. The process is complex and typically takes 30 to 60 business days from initial submission to final approval, though complex applications or requests for supplementary materials may extend this timeline to three months or more. Depending on the scale of your operations, the authority managing your application will differ:

Provincial Operations: Approved by the Provincial Communications Administration Bureau (省通信管理局) where the company is registered.

Cross-Provincial Operations: Must apply to the Ministry of Industry and Information Technology (国家工业和信息化部).

Major filing authorities include:

• Shanghai Communications Administration (上海市通信管理局) for Shanghai
• Beijing Communications Administration (北京市通信管理局) for Beijing
• Guangdong Communications Administration (广东省通信管理局) for Guangdong
• Shenzhen Communications Administration (深圳市通信管理局) for Shenzhen

Step 1: Material Preparation

Confirm enterprise qualifications meet requirements and prepare all application materials organized by category:

• Business license with telecommunications or value-added telecommunications business scope
• Company articles of association
• Legal representative identification and proof
• Technical personnel and management personnel credentials (ID cards, education certificates, work experience proof)
• Office premises proof (lease agreement or property certificate)
• Equipment inventory and system architecture diagrams
• Information security assurance system documentation
• Commitment letter for lawful telecommunications business operations (signed by legal representative and stamped with company seal)

Step 2: Online Submission

Access the Telecommunications Business Market Comprehensive Management Information System (电信业务市场综合管理信息系统). Complete and submit application forms, uploading all materials in PDF format.

Step 3: Material Review and Evaluation

MIIT’s local Communications Administration conducts initial formal review followed by substantive review. The review focuses on:

• Enterprise qualifications and registered capital
• Personnel qualifications and staffing levels
• Equipment configuration and system architecture
• Information security measures and message storage capabilities

If the initial review passes, authorities may conduct an on-site evaluation to verify actual operational conditions, including office premises, equipment, and personnel.

Step 4: Approval and Public Announcement

After passing review and evaluation, the application enters the approval phase. Upon approval, the company information will be publicly announced on the Communications Administration’s official website. If no valid objections are received during the announcement period (typically 15 to 30 days), the process moves to the final stage.

Step 5: Certificate Collection

After the announcement period ends without objections, the company can officially receive the B23 License. Choose on-site pickup or mail delivery. The certificate is valid for 5 years and requires renewal before expiration. Companies must apply for renewal 90 days before expiration and submit all complete materials at least 30 days before expiration, otherwise renewal will not be granted and this is considered automatic abandonment of renewal. Finally, to remain compliant with local laws and regulations, companies are required to display the B23 License number provided on the certificate on their website.

Failure to renew on time may result in being listed on telecommunications bad faith lists.

The entire process generally takes 30 to 60 business days (approximately 2 to 3 months) from submission to approval, though applications requiring additional review or supplementary materials may take up to three months or slightly longer.

What Documents are Required for Application?

According to the Administrative Measures on Telecommunications Business Permits (2017), the following documents are required:

• Company Documents – Business license (营业执照) with telecommunications or value-added telecommunications business scope, company articles of association, legal representative identification, and shareholder identification.
• Personnel Documents – Social security certificates for at least three employees, identification cards of key management and technical personnel, education certificates (degrees and diplomas), and relevant work experience proof or certifications.
• Business Materials – License application form, business development plan, technical solution demonstrating store-and-forward system capabilities, service quality assurance plan, and operational procedures.
• Infrastructure Documents – System architecture diagrams showing message storage and forwarding infrastructure, equipment inventory lists with specifications (mail servers, storage systems, network equipment, etc.), office premises proof (lease agreement or property certificate), and platform functionality documentation.
• Compliance Documents – Information security assurance system documentation, cybersecurity department establishment records, data protection regulations and procedures for stored messages, incident response plans, operational security policies, and commitment letter for lawful telecommunications business operations (signed and stamped).

All copies must be stamped with your company seal. Foreign language documents require certified Chinese translations. Requirements will vary by province and local Communications Administration. Due to the complexity of this process, it is recommended you work with a partner that is familiar with this process, such as AppInChina. This will not only reduce application delays, but will also increase the likelihood of the application being successful.

What Are the Consequences of Operating Without a B23 License?

Operating telecommunications or store-and-forward messaging services in China without a valid B23 License directly violates Chapter 6 of the Telecommunications Regulations of the People’s Republic of China (中华人民共和国电信条例) and carries significant legal and operational risks:

• Criminal liability for serious offenses such as unauthorized telecommunications operations.
• Administrative penalties including warnings, rectification orders, and confiscation of illegal gains.
• Fines calculated as 3 to 5 times the amount of illegal income; if there is no illegal income or it is less than CNY 50,000, fines ranging from CNY 100,000 to CNY 1 million will be imposed.
• Business restrictions including suspension of operations, forced shutdown of messaging services, or revocation of telecom permits in severe cases.
• Blacklisting of the entity and key personnel, preventing future telecommunications business operations.
• Additional liability for companies and approval agencies if services are carried out during the application process before license approval.

You cannot operate store-and-forward services while your B23 License application is pending. Both your company and the approval agency will face penalties if unlicensed operations are discovered during the application period.

How Can AppInChina Help?

Navigating China’s B23 license requirements demands specialised expertise and a local entity. We can help with: 

• Compliance Assessment. We provide a free assessment of your solution to determine which licenses you require, which may include the B23 License and other licenses, filings and certificates. Based on this we will confirm what options are available to you.
• Publishing. AppInChina can obtain the B23 License on your behalf and publish your solution under our company. 
• License Application. If you’re trying to obtain the B23 License for your wholly foreign-owned enterprise (WFOE) in China then we can advise you on this process. 

Contact us to book an initial call and begin your entry into the Chinese market.