How To Deploy Social Functions On Your Platform in China

China’s digital ecosystem is home to over 1.3 billion daily active users that interact with social functions. As a result, systems have been put in place to mitigate misuse of these functions. This guide will outline the legal foundation of social functions in China and will explain what is needed for apps to implement social functions.

What are Social Functions? 

According to Article 2 of the Provisions on the Security Assessment of Internet-based Information Services with Attribute of Public Opinions or Capable of Social Mobilization, social functions are defined by the Cyberspace Administration of China (CAC) as any online platform:

1.  Providing such information services as forums, blogs, microblogs, chat rooms, communication groups, public accounts, short videos, online streaming, information sharing and mini programs, etc. or setting up corresponding functions; and

2. Providing other Internet-based information services that offer channels for expressing public opinions or that are capable of mobilising the public to carry out specific activities.

What Platforms Use Social Functions in China?

Based on the official definition, apps with social functions include:

• Forums
• Blogs
• Microblogs (like Weibo)
• Chat rooms
• Communication groups (like WeChat groups)
• Public accounts (official accounts on platforms such as WeChat or Weibo)
• Short videos (like Douyin)
• Online streaming/live broadcasting
• Information-sharing platforms
• Mini programs (小程序)

What are the Legal Requirements for Social Functions in China?

In the Provisions on the Security Assessment of Internet-based Information Services with Attribute of Public Opinions or Capable of Social Mobilization, it is stated that a security assessment (安全评估) is also required by platforms using social functions. 

What is the Security Assessment?

Article 5 requires a comprehensive assessment of:

1. Security management personnel and information review staff appropriate to services provided
2. User real identity verification and registration information retention measures
3. User activity logging (accounts, operation times, types, network addresses, ports, hardware characteristics, published content)
4. Prevention of illegal/harmful information in usernames, group names, content, etc.
5. Personal information protection and technical measures preventing illegal information spread and social mobilization risks
6. Complaint and reporting systems with published methods and timely handling
7. Technical/data support mechanisms for cyberspace administration supervision
8. Technical/data support mechanisms for public security and national security organs 

According to Article 3, providers must conduct security assessments (安全评估) when:

1. Services with social functions go online or add related functions
2. New technologies cause major changes to public opinion attributes or social mobilization capability
3. User scale significantly increases, causing major changes to public opinion attributes
4. Illegal/harmful information spreads, indicating existing security measures are inadequate
5. Authorities at the provincial level or above notify in writing that assessment is required.

Are There Any Additional Requirements?

Article 6 requires that security assessment reports include “relevant license and certificate” information, indicating additional licensing beyond basic ICP may be required depending on the platform and its other functions. The security assessment itself becomes a mandatory compliance requirement separate from ICP Filing.

Content review is also necessary. This includes reviewing content before and after it is released. This can be done through an automatic content review API and/or manually. To learn more about how to deploy content review in China, read our full guide. 

Do I Need to Include a Report Function?

Yes. This is explicitly mandatory. Article 5(6) specifically requires “establishing complaint and whistleblowing systems, announcing information such as complaints and reporting methods, and accepting and handling relevant complaints and whistleblowing in a timely manner”. Any apps or platforms with social functions must include some form of a reporting function to maintain compliance with regulatory requirements.

Do Users Need to Do Real-Name Verification? 

Yes. Chinese law mandates real-name verification (实名认证) for all solutions offering social or interactive features to ensure user accountability and content traceability. This requirement stems from the Cybersecurity Law of the PRC, Article 24, which requires platforms to verify users’ real identity before allowing access to publishing or interactive functions.

Ongoing Compliance and Monitoring

Articles 8 to 13 establish ongoing regulatory oversight, including:

• Written review by authorities
• Potential on-site inspections
• Expert reviews for high-risk services
• Public risk notifications for non-compliance
• Supervision and legal penalties for violations 

This official regulation establishes a comprehensive compliance framework for apps with social functions that goes significantly beyond basic ICP licensing, requiring:

1. Mandatory security assessments before launch and during operation
2. Formal reporting to government platforms
3. Real-name verification systems
4. Comprehensive logging and monitoring
5. Complaint/reporting mechanisms
6. Technical cooperation with authorities
7. Ongoing regulatory oversight and potential inspections

The regulation has been in effect since November 30, 2018, and applies to any app offering social interaction, content sharing, or public communication capabilities

How Can AppInChina Help?

At AppInChina, we provide full compliance assessments for our clients to ensure that they establish a fully compliant presence in the Chinese market. This will often include evaluations of platforms and their various functions. We can help by:

• Providing you with a free compliance assessment to inform you of what you need to stay compliant in China
• Localising your platform for the Chinese market. This includes both content localisation and technical localisation, such as setting up a report function to ensure compliance. 
• Managing ongoing support to ensure your solution remains compliant in China’s digital ecosystem.

Contact us to schedule a free call with our team to get started with your entry into the biggest digital market in the world.