The Complete Guide to China’s ICP License (B25)

By Marcos SabioLast Updated on Sep 5, 2025

One of the most important licenses for commercial internet operations in China is the ICP License, also known as the B25 License or ICP许可证. Understanding this commercial internet license is essential for any business planning to generate revenue through digital services in China.

This guide will address all of the key questions regarding the ICP License such as the legal foudation, how to apply for one, and how to ensure that you remain compliant.

What is the ICP License (B25)?

The ICP License, formally known as the “Internet Information Service License” (互联网信息服务许可证) or B25 Commercial ICP License, is a commercial operating license required for businesses that provide paid internet information services in Mainland China. Unlike the basic ICP Filing which is free and required for all websites, the ICP License is specifically designed for commercial operations that generate revenue through online activities.

The B25 designation refers to the specific category within China’s telecommunications business classification system, where “B25” represents “Information Service Business (Limited to Internet Information Services)” or 信息服务业务(仅限互联网信息服务).

This license serves as the government’s primary mechanism for regulating commercial internet activities, ensuring that businesses operating for profit in China’s digital market comply with local laws, pay appropriate taxes, and maintain proper oversight of their commercial activities.

What is the Legal Foundation for the ICP License?

The ICP License requirement is not optional, it is mandated by Chinese law under the “Administrative Measures for Internet Information Services” (互联网信息服务管理办法). Understanding the legal foundation helps clarify why commercial operations cannot operate legally in China without the ICP License.

The Legal Definition of Commercial Internet Services

Article 3 of the regulations provides clear definitions that directly apply to all forms of online commercial operations in China:

“Internet-based information services are divided into services of a commercial nature and services of a non-commercial nature.

Commercial internet-based information services refer to compensatory services which provide information to or create web pages for online users through the Internet.

Non-commercial internet-based information services refer to non-compensatory services which supply, through the Internet, to online users information which is open to and shared by the general public.”

The Legal Requirement

Article 4 establishes the mandatory licensing framework:

“The State shall implement a license system for internet-based information services of a commercial nature, and implement a filing-for-record system for internet-based information services of a non-commercial nature.

No one shall engage in internet-based information services without having obtained a license or having completed the filing-for-record procedures.”

It is important to note that this applies to all forms of commercial activity, no matter the size of operation, the business model or the client base (i.e, B2B or B2C). 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) also applies to the Commercial ICP License.

Article 7 establishes that all telecommuncations businesses will 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 telecommuncations.

“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.“

Classification of Value-Added Services

According to the appendix of the Telecommunications Regulations, Internet information service is specifically listed as item (8) under “Value-added telecommunications services”

What is the Difference Between the ICP License and the ICP Filing?

Many businesses struggle to understand when they need an ICP License as opposed to an ICP Filing. The distinction is fundamental and based on the commercial nature of your online activities:

ICP Filing (ICP备案) – For Non-Commercial Activities

Purpose: Basic registration for informational websites
Cost: Free
Use Cases: Corporate websites, blogs, informational portals, product showcases
Revenue: No revenue should be involved with the ICP Filing as any platforms with just an ICP Filing will have no paid products or paywalls to access information.

ICP License (ICP许可证) – For Commercial Activities

Purpose: Commercial operating permit for revenue-generating services
Cost: Licensing fees plus ongoing compliance costs
Use Cases: Paid content services, online marketplaces, subscription services, SaaS platforms, apps
Revenue: Any form of online revenue generation or commercial transactions

It is important to note that the large majority of commercial operations in China require both an ICP Filing and an ICP License. For example, if you operate an e-commerce website that displays product information (requiring ICP Filing) and processes online transactions (requiring ICP License), you need both registrations.

Who Needs an ICP License?

The ICP License is mandatory for businesses engaged in any form of commercial internet activities this includes, but is not limited to:

E-commerce and Online Retail

Online stores and marketplaces
B2B and B2C trading platforms
Product sales websites with payment processing
Cross-border e-commerce platforms

Digital Content and Media Services

Paid content platforms and subscription services
Online gaming platforms (in conjunction with other gaming licenses)
Streaming services for paid content
Digital publishing and media distribution

Online Service Platforms

Professional service marketplaces
Software-as-a-Service (SaaS) platforms with paid subscriptions
Online education platforms with paid courses
Digital consulting and advisory services

Financial and Fintech Services

Online payment processing (requires additional financial licenses)
Digital lending platforms
Investment and trading platforms
Cryptocurrency-related services (heavily restricted)

What Basic Requirements are there for ICP License Application?

According to MIIT regulations, companies applying for Value-Added Telecommunications licenses must meet these mandatory conditions:

1. Legal Entity Status: Must be a legally established company registered in China

2. Financial Requirements:

Provincial operations: Minimum RMB 1 million registered capital
Cross-regional operations: Minimum RMB 10 million registered capital

3. Technical and Human Resources: Must have appropriate funding and professional personnel suitable for the business activities

4. Service Capability: Must demonstrate credibility and capability to provide long-term services to users

5. Infrastructure Requirements: Must have necessary premises, facilities, and technical solutions

6. Clean Record: The company and its major investors and senior management cannot be listed on the telecommunications business operations blacklist

7. Compliance History: Cannot have provided false application materials within the past year

Foreign Investment Additional Requirements:

Foreign ownership cannot exceed 50% for Value-Added Telecommunications Services
Must comply with all standard qualification requirements above
Foreign investors must meet specific industry experience and qualification standards

Key Personnel Requirements

According to official MIIT application forms, companies must designate specific responsible personnel:

Permit Responsible Person (许可负责人): A dedicated staff member responsible for permit-related matters and government liaison
Customer Service Responsible Person (客服负责人): Personnel managing customer service operations
Security Responsible Person (安全负责人): Individual responsible for network and information security compliance

All responsible persons must provide valid contact information and meet real-name verification requirements for mobile phone numbers.

Personnel Documentation Requirements

Companies must provide comprehensive personnel verification:

Social Insurance Certificates: Must be issued within one month of application submission, showing recent coverage for all designated responsible personnel
Alternative Documentation: If social insurance certificates cannot be provided, companies may submit salary bank statements, tax payment certificates, or other third-party employment verification materials
Personnel Scale Classification: Companies must declare their current staff size from categories ranging from fewer than 10 employees to over 2,000 employees

Application Form Structure and Components

The official ICP License application consists of several mandatory sections:

Core Application Components

Basic Company Information Form (增值电信业务经营许可证申请表)
- Business license details and scope verification
- Registered capital and legal representative information
- Service coverage area and business type classification
Company and Personnel Information (公司及人员情况表)
- Current business operations and industry classification
- Designated responsible personnel for permits, customer service, and security
- Personnel verification through social insurance or alternative documentation
Network and Information Security Measures (网络与信息安全保障措施)
- Security organization structure and management responsibilities
- Technical security personnel qualifications and duties
- Comprehensive security compliance commitments
Shareholder Traceability and Documentation (股东追溯及其相关证明材料)
- Complete ownership structure with foreign investment disclosure
- Detailed shareholder documentation and verification
- Foreign investment compliance declarations
Legal Operation Commitment Letter (依法经营电信业务承诺书)
- Formal legal compliance commitments signed by legal representative
- Specific operational and regulatory adherence pledges

ICP License applications must be submitted to the communications administration bureau in the province where your business is registered. Each province may have additional specific requirements, processing procedures, and approval criteria. Some provinces are more favorable to foreign investment and may have streamlined processes, while others maintain stricter requirements.

How Can I Get an ICP License?

The ICP License application process is complex and typically takes 2-3months from initial preparation to final approval. This will however depend greatly on multiple factors, including whether or not a Chinese subsidiary has already been established and how fast the required documentation can be prepared.

Stage 1: Pre-Application Preparation

Establish qualified Chinese legal entity (if not already established)
Set up compliant hosting infrastructure in China
Prepare all required documentation and translations
Develop compliance policies and operational procedures
Conduct preliminary consultations with regulatory authorities

Stage 2: Initial Application Submission

Submit complete application package to provincial communications bureau
Pay required application fees
Provide supplementary materials as requested
Schedule technical and compliance reviews

Stage 3: Technical Review and Assessment

Technical capability evaluation by government inspectors
Security and compliance audit of systems and procedures
Personnel qualification verification
Business model and revenue structure review

Stage 4: Public Comment Period

Public notice of application for stakeholder feedback
Regulatory review of any objections or concerns raised
Additional documentation or clarification as needed

Stage 5: Final Review and Approval

Final administrative review and decision
License issuance with specific terms and conditions
Official registration and public record publication

Stage 6: Post-Approval Implementation

License number display on websites and services
Commencement of commercial operations
Initial compliance reporting setup

Generally, 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 applicatio being successful.

Ongoing Compliance and Maintenance

It is required by the MIIT that any system changes or changes to operations under the ICP License must be reported. An annual review should also be conducted by the agency employed for the license application. If the license was achieved without an agency, this review should be done internally in order to ensure ongoing compliance.

What are the Consequences of Operating Without an ICP License?

Operating commercial internet services in China without proper ICP licensing can result in severe penalties. Chapter 6 of the Telecommunications Regulations of the People’s Republic of China 中华人民共和国电信条例 (2016修订) outlines the different penalties that can be issued:

Criminal liability for serious violations (e.g., security breaches, corruption, market disruption).
Administrative sanctions such as warnings, correction orders, and confiscation of illegal income.
Fines ranging from RMB5,000 to RMB1 million, or calculated as multiples of illegal income.
Business restrictions including suspension of operations or revocation of telecom permits in severe cases.
User-focused remedies such as mandatory apologies and compensation for losses.
Specialised oversight by product quality authorities for telecom equipment quality violations.

How Can AppInChina Help with Your ICP License?

Navigating China’s ICP License requirements can be complex and time-consuming. At AppInChina, we provide comprehensive ICP License services to help international businesses succeed in China. We can help by:

Completing application preparation and submission management
Liaising with provincial authorities throughout the approval process, ultimately succeeding in getting the Commercial ICP License.
Managing annual audits and ensuring ongoing compliance.