The Complete Guide to China’s Mobile App Filing

By Marcos SabioLast Updated on Sep 10, 2025

On July 21st, 2023, China’s Ministry of Industry and Information Technology (MIIT) issued the “Notice of the Ministry of Industry and Information Technology on the Record-filing of Mobile Internet Apps.” This notice officially introduced the Mobile App Filing into China’s digital compliance system. This guide covers everything you need to know about obtaining a Mobile App Filing for your app or WeChat Mini Program in China.

What is China’s Mobile App Filing?

China’s Mobile App Filing, or 移动互联网应用程序备案, is a mandatory registration requirement for all mobile applications operating in mainland China. Managed by the Ministry of Industry and Information Technology (MIIT), this filing is an extensions of China’s existing ICP Filing system to mobile apps, ensuring all digital services comply with Chinese internet regulations.

It was announced on September 1st, 2023, that all new apps must complete the Mobile App Filing before publication on Chinese app stores. Existing apps had until March 31st, 2024 to comply or face removal from app stores and potential penalties.

Unlike the ICP Filing that mainly focusses on informational websites, China’s Mobile App Filing specifically targets mobile applications, mini programs, and quick apps distributed through Chinese platforms including the Apple App Store China , Android app stores, WeChat, and Alipay.

Here is an example of a Mobile App Filing. This is Tencent’s Honor of Kings (王者荣耀) and their Mobile App Filing. The mobile app filing will have a Chinese character representing the city in which it was obtained （粤 or 京 are commonly seen, referring to Shenzhen and Beijing) and a filing number in the format of: B2-XXXXXXXX-XXA

What are the Key Requirements to Obtain Mobile App Filing?

Essential Prerequisites:

Chinese legal entity with all required operational licenses
App backend hosted on mainland Chinese servers
Valid ICP Filing for all associated domains and websites
Commercial ICP License (B25) for revenue-generating apps

Required Documentation:

Business license (营业执照) from Chinese legal entity
Legal representative and network security officer ID information
App technical specifications (package name, MD5 signature, platform keys)
All domain names used by the app (2nd, 3rd, and 4th level domains)
App icon (.jpeg format, under 100KB)
Industry-specific licenses if applicable

According to MIIT regulations, failure to complete Mobile App Filing may result in app store removal, service suspension, fines ranging from 5,000 to 50,000 CNY, and potential legal liability.

Who Needs China’s Mobile App Filing?

If you operate a mobile app that provides internet information services in China, Mobile App Filing is required. This includes:

All Mobile Applications:

Native iOS and Android apps
WeChat Mini Programs and Alipay Mini Programs
Quick apps and pre-installed applications

Specific Business Types:

E-commerce apps selling to Chinese consumers
Social media and messaging applications
Gaming apps (require additional game approval numbers)
Educational platforms and online learning apps
Financial services and payment applications
News, publishing, and content-driven apps

It is important to note that, even with a valid ICP Filing for your website, you need separate Mobile App Filing for your mobile applications.

Are There Any Apps Exempt from Mobile App Filing?

Limited exemptions exist for truly offline applications that have no internet connectivity and don’t store or process data online. Examples include basic calculator apps or completely offline games.

Exemption Criteria:

No network services or internet connectivity
No data processing or storage online
No API calls or web service usage
Complete offline functionality

Verification Process: If you believe your app qualifies, contact Apple Developer Support at https://developer.apple.com/contact/ with evidence of offline functionality. However, truly offline apps are rare in today’s connected environment, and misrepresentation can lead to App Store rejection.

What Additional Requirements Exist for Specific Industries?

Apps in restricted categories need additional licenses beyond basic Mobile App Filing:

Restricted Categories Requiring Special Permits:

News & Publishing: Media publishing licenses
Education: Educational authority approvals
Healthcare & Pharmaceuticals: Medical service certifications
Gaming: Game approval numbers from regulatory authorities
Financial Services: Banking and payment licenses
Religion: Religious content permits
Transportation: Ride-hailing service licenses

Gaming Apps: All games, regardless of monetization, require approval numbers from Chinese regulatory authorities in addition to Mobile App Filing.

How to Get Mobile App Filing in China

Here’s a step-by-step guide to obtaining your Mobile App Filing:

1. Establish Chinese Legal Presence

Only Chinese-registered businesses can apply. You’ll need:

Chinese business license
Local legal representative
Network security officer designation

If you don’t have a Chinese entity, AppInChina can help you apply through our established legal entity.

2. Migrate to Chinese Cloud Infrastructure

Your app backend must be hosted on approved Chinese cloud providers:

Alibaba Cloud
Tencent Cloud
AWS China
Azure China
Baidu Cloud

3. Obtain ICP Filing for Associated Domains

All domains used by your app must have valid ICP Filing. This includes:

Main app domains
API endpoints
CDN domains
Third-party service domains

4. Submit Mobile App Filing Application

This is the MIIT Official Filing System website. When creating an application, ensure you have the APP option selected.

Use the Official MIIT Filing System (Chinese only). Submit:

Complete app technical specifications
Business license (营业执照) and legal entity documentation
Legal representative and network security officer ID information
App screenshots and functionality descriptions
Industry-specific licenses if applicable

5. Platform-Specific Submissions

Apple App Store: Submit ICP Filing number during app review process Android Stores: Provide filing information to each Chinese Android app store Mini Programs: File through WeChat or Alipay distribution platforms

6. Await Approval

Processing typically takes 20 working days. MIIT will notify you via SMS and email upon approval.

7. Display Filing Number

Once approved, display your Mobile App Filing number prominently in your app’s Settings or About section.

WeChat’s Mobile App Filing is in the “About” section of the app.

What are the Consequences of Not Having a Mobile App Filing?

Operating without Mobile App Filing results in severe consequences:

Immediate Platform Actions:

Removal from/inability to list on all Chinese app stores
WeChat and Alipay mini program suspension
Network access service termination

Regulatory Penalties:

Fines ranging from 5,000 to 50,000 CNY for missing filing number display
Service shutdown orders from local authorities
Complete market access loss to 1+ billion Chinese mobile users

Business Impact:

Revenue loss from Chinese market
Brand reputation damage
Competitive disadvantage against compliant apps

Mobile App Filing vs. ICP Filing: What’s the Difference?

Both filings are required but serve different purposes:

Feature	ICP Filing	Mobile App Filing
Regulating Body	Ministry of Industry and Information Technology (MIIT)	Ministry of Industry and Information Technology (MIIT)
Purpose	Website domain registration & content regulation	Mobile app registration & platform compliance
When Required	Before launching website hosted in China	Before publishing app in Chinese app stores
Scope	Websites, domains, web services	Mobile apps, mini programs, quick apps
Prerequisites	Chinese entity, China hosting	Chinese entity, China hosting, ICP Filing
Display	ICP number in website footer	Filing number in app settings/about section

What Special Considerations Exist for International Developers?

International app developers face unique challenges:

Mandatory Partnerships:

Cannot apply directly – must work with Chinese legal entities
Need local partners like AppInChina for filing sponsorship
Require ongoing compliance management support

Technical Infrastructure:

Complete backend migration to Chinese cloud providers
Data localization within mainland China
CDN setup through approved Chinese networks

Language and Process Barriers:

All applications must be submitted in Chinese
Technical documentation requires accurate translation
Cultural understanding of regulatory expectations needed

What Are Your Options for Obtaining Mobile App Filing as a Foreign Company?

Since only Chinese entities can obtain Mobile App Filing, international developers must choose between two compliance models:

Option 1: Establish Your Own Chinese Entity

Requirements:

Set up Wholly Foreign-Owned Enterprise (WFOE) or Joint Venture
Minimum registered capital (varies by business scope)
Local registered address and office space
Chinese legal representative appointment
Network security officer designation

Costs:

Entity setup: USD15,000 to USD50,000 or more in legal and administrative fees
Ongoing compliance: USD20,000 to USD40,000 or more annually
Office lease and operational expenses
Full-time local staff requirements

Timeline:

Entity establishment: 3 to 6 months
Commercial ICP License (if needed): 3 to 6 months additional
Mobile App Filing: 1to 2 months after entity setup
Total timeline: 7 to 14 months

Advantages:

Full control over Chinese operations
Direct relationship with regulators
Ability to handle multiple apps and services
Long-term scalability for China market

Disadvantages:

High upfront investment and ongoing costs
Complex regulatory compliance burden
Requires dedicated local team
Lengthy setup process delays market entry

Option 2: Partner with AppInChina