How Can I Publish on the Apple App Store China? 

Publishing your app on the Apple App Store in Mainland China gives your business access to the world’s largest mobile market, with over 200 million iOS users. However, navigating the regulatory landscape and Apple’s requirements can be complex for international developers. This comprehensive guide breaks down everything you need to know about publishing on the Apple App Store China.

Can You Publish in China from Your Global Apple Developer Account?

Yes, you can publish apps in Mainland China using your existing global Apple Developer account. The process is straightforward from a technical standpoint:

1. Select Your Target Region: When submitting your app through App Store Connect, simply select “Mainland China” as one of your target regions.
2. App Availability: Your app will become available to Chinese users once approved.
3. ICP Filing Request: Apple will ask you to provide an ICP Filing (Internet Content Provider Filing or ICP备案) for mobile apps, often referred to as a Mobile App Filing. 

Do I Need an ICP Filing to Publish on the Apple App Store China?

Apple’s approach to ICP Filing enforcement varies depending on your company structure:

• Chinese Companies: Apple is currently enforcing ICP Filing requirements for apps published by Chinese companies in China. It is not possible for a Chinese company to publish on the Apple App Store China without an ICP Filing. 
• International Companies: International companies using their global accounts to publish in China are prompted to provide an ICP Filing, but it is still possible to publish the app without providing one. 

Here’s what international companies need to know about ICP Filings:

Can you publish without it? Currently, yes. Apple allows publication even if you don’t provide an ICP Filing.

Is it legally required? Yes. Every app operating in China is legally required to obtain an ICP Filing. According to article 4 of the Administrative Measures on Internet-based Information Services (互联网信息服务管理办法), all internet-based information services require a license or filing to operate legally. 

What is the risk of not providing an ICP Filing? While not currently enforced by Apple for global developers, this could change. Apple may begin requiring ICP Filings from all publishers, which could mean that your app may be removed from the app store.

ISBN License Enforcement Precedent:

Games on the Apple App Store China provides a clear example of how quickly Apple can change enforcement policies. In February 2020, Apple sent out a notice to developers asking them to submit an ISBN (game license number) by June 30, 2020 for all paid games or games that offer in-app purchases. This regulation, which came into effect in 2016, was suddenly enforced by Apple with a strict deadline:

• July 2020: Apple began rejecting any games without an ISBN. 
• August 1, 2020: 26,575 games were removed from the Chinese App Store before noon.
• First week of July: More than 2,500 mobile games were removed from China’s App Store.
• December 2020: Apple contacted game developers, giving them until Dec 31 to submit game license approval numbers or their games would be removed.

Just as with ISBN licenses for games, the ICP Filing is already a legal requirement for all apps in China, but enforcement by Apple has been selective. The ISBN precedent shows that Apple can and will suddenly enforce Chinese regulations when required, potentially affecting:

• All App Categories:Unlike the ISBN license, which only affected games, ICP Filing applies to all apps.
• Revenue: Apps could be removed, cutting off your company’s revenue from China.
• User Base: Existing Chinese users would lose access to your app.
• Market Position: Years of building rankings and reviews could be lost instantly.

Why Should I Get an ICP Filing as an International Developer?

It is highly recommended that you obtain an ICP Filing as an international developer publishing in Mainland China for two key reasons:

1. Without an ICP Filing, there is a risk that your app will be removed from the Apple App Store China with a short notice period. This is certainly possible, as evidenced in the ISBN enforcement case. 
2. An ICP Filing is a clear legal requirement for every app that is published in China, and your company and staff in China may face legal consequences without one. 

What Methods Can I Use to Publish My App on the Apple App Store China?

Method 1: Publishing Under an International Entity

Current Process:

• Use your existing global Apple Developer account.
• Select Mainland China as a target region.
• Operate without an ICP Filing. 

Advantages:

• No additional costs.
• Faster time to market.
• Simplified revenue management, as you will be publishing under an existing global Apple Developer account. 

Disadvantages:

• Non-compliance with Chinese law.
• Potential future enforcement issues if the ICP Filing requirement is enforced by Apple.

Method 2: Publishing Under a Chinese Subsidiary

Requirements:

• Establish a Chinese subsidiary, if you don’t already have one. 
• Obtain an ICP Filing for your app under this Chinese entity.
• Ensure that the app is fully compliant with all applicable laws and regulations.

Advantages:

• Complete regulatory compliance.
• No risk of future app removal if compliance requirements are met. 
• Direct control over Chinese operations.
• No dependency on third-party partnerships.

Disadvantages:

• Significant upfront investment and ongoing costs.
• Complex legal and administrative requirements.
• Need for local expertise and management.
• Full liability for regulatory compliance.

Method 3: Partnering with a Chinese Entity 

Partnering with a Chinese entity, such as AppInChina, allows you to continue distributing your app in China using your global Apple Developer account. This method assigns a Chinese partner as the official publisher of your app in China, ensuring compliance with local laws and regulations. 

Publishing Structure:

• AppInChina obtains an ICP Filing for your app under our company.
• You can choose to either continue using your existing global Apple Developer account to distribute your app in Mainland China, or have your Chinese partner distribute a separate China-specific version of your app. 

Revenue and Financial Management:

• Continue receiving revenue from China to your global Apple Developer account.
• AppInChina will ensure that Chinese sales tax and withholding tax are paid on your Chinese revenue. 

User Continuity Benefits:

• Existing Chinese users remain completely unaffected.
• No app reinstallation is required for current users.
• Maintain current App Store rankings and reviews.
• Preserve all user data, purchase history, and ongoing subscriptions. 

Apple App Store China Publishing Methods Comparison

Aspect	Method 1: International Entity	Method 2: Chinese Subsidiary	Method 3: Chinese Partner
Setup Complexity	Low – Use existing global account	High – Establish Chinese subsidiary	Low – Partner integration
Cost	None	High – Entity setup and management costs	The international entity is liable
Regulatory Compliance	Non-compliant (high risk)	Full compliance via Chinese subsidiary	Full compliance via partner
ICP Filing	Not currently required by Apple	Obtained by Chinese subsidiary	Obtained by Chinese partner
Tax Obligations	Unchanged	Chinese sales tax + withholding tax	Chinese sales tax + withholding tax
Timeline to Launch	Immediate (if already published)	6-12 months (entity setup)	1 month with AppInChina
Legal Liability	International entity is liable	Chinese subsidiary is liable	Shared liability with Chinese partner

How Can AppInChina Help?

At AppInChina, we offer services in publishing, localisation and promotion for the Apple App Store China. We can help you by:

• Publishing your app in order to ensure compliance and mitigate the risk of your app being removed. This includes a compliance assessment to check if any extra licenses are required for your app to be compliant as well as obtaining a Mobile App ICP Filing for your app. 
• Localising your app and optimising it for ASO (Apple App Store Optimisation)
• Promoting your app through Apple Search Ads and other proven successful channels in China. 

Contact us to book a free consultation call to learn more about our services.