The Complete Guide to China ICP Filing Traffic Compliance
Operating a website or mobile application in China requires an ICP Filing (ICP备案) or a Mobile App Filing (APP备案), respectively. One of the most common questions from businesses is, “Where must ICP-filed domain and app traffic actually terminate?”
The answer is clear: traffic must terminate on the server/IP addresses declared in the filing. This guide explains the legal basis behind this requirement, how it is enforced by cloud providers such as Aliyun, the risks of non-compliance, and how businesses can deploy their website or application in a compliant manner.
Do ICP-Filed Domains Need to Route Traffic to a Specific Server?
Yes. An ICP-filed domain’s DNS records must resolve exclusively to the server and IP address declared in the ICP filing.
The Measures for the Filing of Non-Commercial Internet Information Services (非经营性互联网信息服务备案管理办法) provides the foundation for this requirement:
- Articles 5 through 7 detail that websites operating in China need to obtain an ICP Filing. These articles also stipulate that a domain name and IP address is required to complete this process.
- Article 14 highlights that any changes made to the filing details (e.g., server migration) must be reported within 30 days of the change occurring.
- Article 18 states that cloud providers must not provide services to domains whose filing is inaccurate or to domains that do not possess an ICP Filing.
- Article 19 states that cloud providers must record filing information, conduct dynamic management of user information, preserve access logs, and supervise compliance with filed information.
- Article 20 states that provincial telecommunications administrations will conduct an annual review of ICP filings using the Ministry of Industry and Information Technology’s (MIIT) centralised filing system.
- Article 21 details that filing holders themselves must log into the MIIT system annually to complete review procedures, ensuring that all information (including server IPs and domains) remains accurate.
- Article 23 states that anyone who violates Article 7 hereof by providing false information for filing, his/her website will be closed down by the provincial telecommunications administration at the locality of his/her domicile, and his/her filing will be nullified.
Therefore, in practice, when you file an ICP, you must register both your domain names and IP addresses. By law, if either changes, you must update the filing.
Chinese Cloud providers (such as AWS China, Azure China, Huawei Cloud, Tencent Cloud, and Aliyun) enforce this by checking that your domain’s DNS always points to an IP that belongs to the same provider you filed with. If your traffic goes elsewhere, the filing is invalid, and your site/app can be taken offline. This means your filed domain must always resolve to the filed server IP at the filed provider.
Note: The above requirements also apply to the Commercial ICP License (B25).
How is this Requirement Enforced?
As detailed above, all Chinese cloud providers must enforce MIIT’s rules. Aliyun’s public policies show how this works in practice and explicitly state that all traffic must terminate on the IP address included in the ICP Filing.
| Enforcement Method | Implementation Details |
| Access Accuracy Checks (接入准确性核查) | Aliyun periodically checks whether filed domains actually resolve to Aliyun’s Mainland China servers. Domains pointing elsewhere, or with no real traffic, are flagged as inaccurate. |
| Server Location Checks | Only servers located in Mainland China nodes can be used for filing. Overseas servers (Hong Kong, Singapore, etc.) are ineligible. |
| Content Delivery Network (CDN) or Web Application Firewall (WAF) Rules | If using a third-party CDN or WAF, the origin must still be within the filed provider’s Mainland China infrastructure, and return-to-origin (回源) traffic must include the filed domain in the Host header. |
| Traffic Consistency Requirement (真实有效接入) | Filing requires actual, consistent access patterns. If DNS resolution exists but traffic is missing or irregular, the filing may be invalidated. |
Below is a flowchart of the ICP Filing application process that demonstrates the collaboration between cloud providers and MIIT when it comes to enforcing the above regulations.
Cloud providers and MIIT work together to ensure that all information and documents provided in the application are legitimate. During this process, domain and IP addresses are also checked.
What are the Consequences of Non-Compliance?
The Measures for the Filing of Non-Commercial Internet Information Services (非经营性互联网信息服务备案管理办法) establishes specific penalties for violations:
- Article 22 states that operating without filing or beyond the filed scope results in a CNY 10,000 fine with website closure for refusal to correct. Providing services in excess of filed items leads to CNY 5,000 to 10,000 fines with potential filing nullification.
- Article 23 mandates immediate website closure and filing nullification by provincial telecommunications administration for anyone providing false filing information.
- Article 26 requires a CNY 10,000 fine plus correction orders for failing to report filing changes within required timeframes.
- Article 27 allows provincial telecommunications administration to temporarily close websites or close and nullify filings when services violate state legal provisions, based on authorised agency opinions.
- Article 28 permits website closure and filing nullification for annual review non-compliance, including failing to submit review information on time or receiving government agency vetoes during review.
It is important to note that correct traffic termination is key to staying compliant with MIIT’s detailed ICP Filing requirements. AppInChina can fully manage your ICP Filing for your website in China.
Do Filed Mobile Apps Need to Route Traffic to Specific Servers?
Yes. Mobile applications that complete a Mobile App Filing (APP备案) must route all network traffic to servers/IP addresses declared in the filing.
The legal foundation for mobile app traffic routing requirements comes from two key laws:
- MIIT Notice on Mobile Internet Application Filing Work (工业和信息化部关于开展移动互联网应用程序备案工作的通知) requires app operators (APP主办者) to obtain filing through their network access service providers, with network access service providers prohibited from providing services to unfiled apps.
- Anti-Telecom and Online Fraud Law Article 23 (中华人民共和国反电信网络诈骗法) states that those who wish to establish mobile Internet applications shall go through licensing or filing formalities with the telecom authorities according to relevant provisions of the State.
How is this Requirement Enforced?
As with domains, cloud providers must enforce MIIT’s requirements for Mobile App Filing (APP备案). Baidu Cloud’s documentation and MIIT’s Notice on Mobile Internet App Filing (2023) provide the compliance framework:
| Enforcement Method | Implementation Details |
| Access Accuracy Checks (接入准确性核查) | Apps must be deployed on the servers specified in the filing. Providers validate that backend APIs and service endpoints match the filed information. |
| Server Location Restriction | Only servers located in Mainland China nodes are eligible for app filing. Backends hosted overseas (including Hong Kong) are ineligible for filing. |
| App Information Verification | Filing requires app name, package name, download channel, and backend server/domain. Any inconsistency leads to rejection. |
| Traffic Consistency Requirement (真实有效接入) | Filed apps must demonstrate consistent, real traffic through the filed servers. If DNS resolution exists but traffic is missing, the filing can be invalidated. |
| App Store and Distribution Enforcement | App stores and platforms are prohibited from publishing or updating apps without a valid filing or with inaccurate filings. |
How to Stay Compliant During Infrastructure Changes
Compliance obligations do not end once the initial filing is approved. Businesses must actively maintain alignment between their filed information and their actual infrastructure. To remain compliant during server migrations, scaling, or other infrastructure changes:
- Any change to server IPs or domains must be updated in the filing within 30 days, as required by MIIT.
- When changing hosting providers, cancel the existing access filing before submitting a new one with the replacement provider.
- Regularly verify that filed domains continue to resolve exclusively to the IP addresses declared in the filing.
- Ensure that return-to-origin traffic always points back to the filed infrastructure, including correct host headers.
By proactively managing these obligations, businesses can avoid suspension, penalties, or nullification of their filings.
How Can AppInChina Help?
AppInChina assists international businesses with:
- Meeting ICP Filing basic requirements by filing for your ICP Filing or Mobile App Filing under our own Chinese entity.
- Traffic compliance audits to ensure your ICP Filing is compliant and remains compliant.
- App and website infrastructure migration consulting to ensure that you remain compliant even if your website and/or app infrastructure changes.
- Ongoing monitoring to keep your app website and/or app compliant with Chinese law, ensuring that it is consistently up and running.
With strict enforcement by both MIIT and Chinese cloud providers, compliance is not optional. AppInChina ensures your services stay online and compliant in China.