The Complete Guide to China’s ICP Filing
China’s digital landscape is governed by strict regulations, and one of the most critical requirements for businesses operating online is the ICP Filing. If you’re planning to launch a website or digital service in China, understanding the Internet Content Provider Filing system is essential for legal compliance and successful market entry.
What is ICP Filing in China?
ICP Filing, or Internet Content Provider Filing (ICP备案), is a mandatory registration system established by the Chinese government to regulate and monitor internet content and services within mainland China. It is often misnomered and mistaken for the ICP License which is a different license altogether. The ICP Filing system requires all websites and online services hosted on servers located in mainland China to obtain proper registration before going live.
The ICP Filing system serves as China’s primary mechanism for internet governance, ensuring that all digital content and services comply with local laws and regulations. Without valid ICP Filing, websites cannot legally operate in China and will be blocked by the Great Firewall.
What’s the Difference Between ICP Filing and Commercial ICP License?
It’s important to distinguish between ICP Filing (ICP备案) and the Commercial ICP License (ICP许可证). ICP Filing is the basic, free registration required for all non-commercial websites and informational platforms. This includes corporate websites, blogs, informational portals, and any website that doesn’t engage in direct commercial transactions or revenue generation.
ICP Filing is suitable for businesses that want to establish an online presence in China through informational websites, company portals, or content platforms that don’t process payments or facilitate commercial transactions. The Commercial ICP License, sometimes referred to as the Commercial ICP License is for business whow wish to engage in commercial transactions in China.
This is a fundamental differentiation that companies often struggle with. If you are a company that has an informational website about the products you are selling and then direct users to buy the product, you will need both the ICP Filing and Commercial ICP License. In most cases, companies engaging in commercial transactions will need both the ICP Filing and Commercial ICP License.
Who Needs ICP Filing in China?
It is worth noting that, while websites can still be visible without an ICP Filing if they haven’t been blocked in China. The ICP Filing ensures that your business’s website is always compliant and does not suddenly fail to load due to it being blocked.
ICP Filing is a legal obligation for:
Corporate Websites: Companies wanting to establish an official online presence in China must obtain ICP Filing for their corporate websites, product showcases, and informational portals.
Foreign Company Websites: International businesses with informational websites hosted on Chinese servers need ICP Filing to ensure legal compliance and accessibility within China.
Content Platforms: Non-commercial blogs, news sites, educational platforms, and informational websites require ICP Filing to operate legally.
Subsidiary Websites: Chinese subsidiaries of foreign companies must obtain ICP Filing for their local websites, even if the parent company operates internationally.
Apps and other digital assets such as WeChat Mini Programs require their own ICP Filing.
What Are the Requirements for ICP Filing?
The requirements for ICP Filing focus on basic compliance and informational accuracy:
For Foreign Companies
Foreign companies can obtain ICP Filing through several structures:
Representative Offices: Foreign representative offices in China can apply for ICP Filing for basic informational websites that don’t engage in commercial activities.
Wholly Foreign-Owned Enterprises (WFOE): Foreign companies with established WFOEs can apply for ICP Filing through their Chinese legal entity.
Partnership with Chinese Companies: Some foreign businesses work with Chinese partners, such as AppInChina who can sponsor their ICP Filing applications.
Documentation Requirements
All ICP Filing applicants must provide:
Business Documentation: Valid business licenses, registration certificates, and legal entity verification documents.
Legal Representative Information: Identification documents and contact information for the legal representative or responsible person.
Domain Registration: Proof of domain ownership and registration certificates for all domains requiring filing.
Hosting Agreements: Contracts with approved Chinese hosting providers confirming server location and technical specifications.
Provincial Filing Requirements
You must complete ICP Filing in the same province where your business license was issued. This geographical requirement ensures proper jurisdictional oversight and compliance with local regulations. Foreign companies should consider this when selecting their WFOE registration location. To check if there are any provincial specific requirements for where your business is located, refer to this guide.
Website Information: Detailed descriptions of website content, purpose, and target audience.
Technical Requirements
Websites applying for ICP Filing must meet specific technical standards:
Chinese Server Hosting: All website files and databases must be hosted on servers physically located within mainland China.
Approved Hosting Providers: Websites must use hosting services from government-approved providers such as Alibaba Cloud, Tencent Cloud, Baidu Cloud, or China Telecom.
Domain Registration: Domains must be properly registered and owned by the applying entity or individual.
Content Compliance: Website content must comply with Chinese internet content regulations and guidelines.
How Do I Get an ICP Filing?
The ICP Filing process is streamlined compared to commercial licensing but still requires careful attention to detail:
Stage 1: Pre-Application Preparation
Begin by establishing your legal presence in China if you’re a foreign company. Alternatively, choose a trusted local partner, such as AppInChina, who can help you file for the ICP Filing. Ensure you have all required documentation and that your website content complies with Chinese regulations. Select an approved Chinese cloud hosting provider who will facilitate your ICP Filing application.
Stage 2: Hosting Provider Setup
Choose your Chinese hosting provider and set up your hosting account. Major providers offer dedicated ICP Filing support services and will guide you through their specific submission requirements. Upload your website files to the Chinese servers and configure your technical setup. There are many cloud providers in China who can help host your website, popular choices include:
These popular cloud providers all provide ICP Filing application services and assisstance.
Stage 3: Application Submission
Submit your ICP Filing application through your hosting provider’s management platform. This involves uploading all required documentation, providing detailed website information, and confirming technical specifications. Your hosting provider will conduct an initial review to ensure completeness.
Stage 4: Initial Review
The hosting provider performs a preliminary review of your application, checking for completeness and obvious compliance issues. They may request additional documentation or clarifications during this stage. Once satisfied, they forward your application to the relevant provincial communications administration bureau.
Stage 5: Government Review
Provincial communications administration bureaus conduct the official review of ICP Filing applications. This process typically takes 20 business days from submission. Authorities verify all documentation, review website content for compliance, and may request additional information or modifications.
Stage 6: Approval and Implementation
Upon approval, you receive your ICP Filing number (ICP备案号), which must be prominently displayed on your website. This number typically follows the format “省份简称ICP备XXXXXXXX号”(省份简称 refers to Region Abbreviation – this will reflect the region where the ICP is filed. 京 is Beijing for instance). With your ICP Filing number, your website can legally operate within China’s internet ecosystem. Your ICP Filing number will be publically available in an online database for companies to verify.
To read more about how to get an ICP Filing or an ICP Commercial License, read our complete guide.
What Are the Common Challenges in ICP Filing?
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While ICP Filing is more straightforward than commercial licensing, businesses still face several challenges:
Language and Communication Barriers
All ICP Filing applications and communications must be conducted in Chinese. Foreign companies should work with local partners or professional services that can provide accurate translations and navigate cultural nuances in the application process.
Documentation Accuracy
Chinese authorities require precise documentation with exact matches between business information, domain ownership, and hosting arrangements. Any discrepancies can result in application delays or rejections.
Content Compliance
Understanding and adhering to China’s content guidelines is crucial for successful ICP Filing. Websites must avoid prohibited content categories and implement appropriate content management policies.
Technical Configuration
Properly configuring hosting arrangements and ensuring all technical requirements are met can be challenging for businesses unfamiliar with Chinese internet infrastructure requirements.
How Long Does ICP Filing Take and What Does It Cost?
ICP Filing timelines are generally predictable and costs are minimal:
Processing Time: Standard ICP Filing applications take 20 business days for government review, with additional time needed for preparation and hosting setup.
Direct Costs: ICP Filing itself is free, though businesses incur costs for Chinese hosting services, domain registration, and professional assistance.
Preparation Time: Allow 1-2 weeks for document preparation and hosting setup before submitting your application.
Total Timeline: Most businesses should plan for 6-8 weeks from initial preparation to final approval.
How Do You Maintain ICP Filing Compliance?
Successful ICP Filing requires ongoing compliance and maintenance:
Annual Verification
ICP Filing requires annual verification to confirm continued compliance and accuracy of registered information. This process involves updating any changes to business information, contact details, or website content.
Content Management
Websites must maintain compliance with Chinese content regulations and implement appropriate content moderation where necessary. Regular content audits help ensure continued compliance.
Technical Maintenance
Maintain your hosting arrangements with approved Chinese providers and ensure your website remains accessible and functional. Any significant technical changes should be reported to authorities.
Information Updates
Notify authorities of any changes to business structure, legal representatives, domain ownership, or website purpose. Keeping your ICP Filing information current is essential for maintaining compliance.
What Happens If You Operate Without ICP Filing?
Operating a website in China without proper ICP Filing can result in serious consequences:
Website Blocking: The Great Firewall immediately blocks websites operating without valid ICP Filing once detected, making them inaccessible to Chinese users.
Financial Penalties: Fines ranging from CNY 10,000 to 50,000 can be imposed on businesses operating non-compliant websites.
Hosting Suspension: Chinese hosting providers are required to suspend services for websites without proper ICP Filing.
Legal Liability: In severe cases, website operators may face criminal liability for violations of internet regulations.
What Are the Best Practices for Successful ICP Filing?
Maximize your chances of successful ICP Filing with these proven strategies:
Work with Experienced Partners
Engage local partners or professional service providers with proven experience in ICP Filing such as AppInChina. Their expertise can prevent common mistakes and accelerate the approval process.
Prepare Comprehensive Documentation
Gather all required documents well in advance and ensure accuracy and consistency across all materials. Double-check translations and verify that all information matches exactly.
Choose Reliable Hosting Providers
Select established, government-approved hosting providers with strong track records in supporting ICP Filing applications. Their guidance and support services are invaluable during the process.
Plan Content Carefully
Develop website content that clearly complies with Chinese regulations and accurately reflects your business purpose. Avoid ambiguous content that might raise compliance concerns.
Allow Adequate Time
Start your ICP Filing process well before your planned launch date. Build buffer time into your timeline to accommodate potential requests for additional information or minor delays.
What is China’s PSB Filing and Why Do You Need It After ICP Filing?
After successfully obtaining your ICP Filing, there’s a crucial additional step that many businesses overlook: Public Security Bureau (PSB) Filing, known in Chinese as the 公安备案. You must apply for PSB Filing within 30 days of receiving your ICP Filing approval or your website going live.
What is China’s PSB Filing?
PSB Filing is a criminal background check required for all websites and applications hosted in China. This additional registration ensures that website operators are not involved in criminal or illegal activities and provides another layer of government oversight for internet content.
PSB Filing Process: The PSB Filing application is conducted online through the Internet Security Administration of the National Public Security Bureau of China. The process typically takes 3-5 working days once you submit all required documentation.
PSB Display Requirements: Once approved, you receive a PSB Filing number that must be displayed in your website footer, along with a clickable PSB logo that links back to your registration details on the government website.
For more information on the PSB Filing, read our complete guide.
How Should You Display Your ICP Filing Number?
Once approved, your ICP Filing number must be properly displayed on your website or app:
Prominent Placement: Display your ICP Filing number at the bottom of your website/app ‘shomepage and on other main pages.
Proper Format: Use the complete ICP Filing number as provided by authorities, including the correct format and characters.
Linking Requirements: In some provinces, the ICP Filing number must be linked to the government’s ICP Filing verification website.
Consistent Display: Ensure the ICP Filing number appears consistently across all pages and remains visible and legible.
PSB Number Display: If required to obtain PSB Filing, display both your ICP Filing number and PSB registration number with appropriate government links.
Does ICP Filing Apply to Mobile Apps in China?
Yes, since September 1, 2023, ICP Filing requirements have been extended to mobile applications, creating new compliance obligations for app developers and publishers.
New Mobile App Requirements: All new mobile apps must undergo ICP Filing before they can be published on app stores in China. This requirement applies to Apple App Store, all Chinese Android app stores, and mini-program platforms.
Existing App Deadline: Apps that were already published before August 31, 2023, had a grace period until March 31, 2024, to complete their ICP Filing. Non-compliant apps face removal from app stores and potential penalties.
App Store Enforcement: Chinese authorities now conduct regular inspections of app store listings to verify ICP Filing compliance. Apps without proper filing are removed from distribution platforms.
Mobile App Filing Process: Mobile app ICP Filing follows similar documentation requirements as websites but includes additional technical specifications related to app functionality and data handling.
Different industries may face specific requirements or considerations during ICP Filing:
Technology Companies: Software and technology companies should clearly describe their products and services while ensuring compliance with data protection regulations.
Educational Institutions: Schools and educational organizations may need additional documentation regarding their educational mission and student data protection measures.
Healthcare Organizations: Medical and healthcare websites face stricter content guidelines and may require additional certifications.
Are There Industry-Specific ICP Filing Considerations?
Different industries may face specific requirements or considerations during ICP Filing:
Technology Companies: Software and technology companies should clearly describe their products and services while ensuring compliance with data protection regulations.
Educational Institutions: Schools and educational organizations may need additional documentation regarding their educational mission and student data protection measures.
Healthcare Organizations: Medical and healthcare websites face stricter content guidelines and may require additional certifications.
Manufacturing Companies: Industrial and manufacturing businesses should focus on product information and avoid claims that might require additional regulatory approval.
What Are the Performance Benefits of Chinese Hosting?
Beyond legal compliance, hosting your website on Chinese servers with proper ICP Filing provides significant performance advantages:
Faster Loading Speeds: Websites hosted on Chinese servers load significantly faster for users in mainland China, improving user experience and engagement.
Better SEO Performance: Chinese search engines like Baidu favor websites hosted domestically with proper ICP Filing, potentially improving search rankings.
Reduced Latency: Local hosting eliminates the latency associated with international data transfers, providing smoother browsing experiences.
CDN Access: ICP Filing enables access to Chinese Content Delivery Networks (CDNs), further optimizing website performance across different regions of China.
What Are Recent Changes to ICP Filing Regulations?
China’s ICP Filing regulations have undergone significant updates in recent years:
Mobile App Extension (2023): The most significant change was extending ICP Filing requirements to mobile applications, affecting thousands of international apps.
Enhanced Enforcement: Authorities have increased inspection and enforcement activities, with regular audits of website and app compliance.
Provincial Coordination: Improved coordination between provincial authorities has streamlined the filing process while maintaining strict compliance standards.
Data Security Integration: ICP Filing now incorporates broader data security and privacy requirements, reflecting China’s evolving digital governance framework.
How Can AppInChina Help?
ICP Filing represents the foundational requirement for establishing a legal online presence in China. While the process requires careful preparation and attention to detail, it provides businesses with legitimate access to China’s massive digital market.
At AppInChina, we offer comprehensive Commercial ICP Filing services, these include:
- A free consultation to determine whether you need an ICP Filing, a Commercial ICP License, or both.
- Hosting your website in China under your own entity or under our entity. (Hosting your website or solution under our Chinese legal entity)
- Hosting your website or solution under your own Chinese legal entity
- Helping you obtain an ICP Filing for your website or solution under our own entity and cloud accounts.
- Ensuring you stay compliant with ICP guidelines once you have received it, this includes ensuring the helping you obtain the PSB Filing within the 30 days specified by the Public Security Bureau.
Contact us today to get started!