What is China’s Blockchain Information Service Filing?

A foreign company planning to operate a blockchain-based platform, application, node, or technical service in China may need to complete a Blockchain Information Service Filing with the Cyberspace Administration of China, or CAC known in Chinese as 区块链信息服务备案. 

This filing is separate from China’s ICP Filing, mobile app filing, cybersecurity requirements, and industry-specific licences. It also does not authorize cryptocurrency trading, token issuance, or any other activity that is restricted or prohibited in China.The filing rules apply more broadly than many companies expect. They can cover not only the operator of a public blockchain application but also nodes and organizations providing technical support for a blockchain information service.

This guide explains which services need to file, what information must be submitted, how the process works, and what foreign companies should prepare before launching a blockchain project in China.

What Is China’s Blockchain Information Service Filing?

Blockchain Information Service Filing is a registration system administered by the CAC under the Provisions on the Administration of Blockchain Information Services, which took effect on 15 February 2019.

The rules define a blockchain information service as an information service provided to the public through websites, applications, or similar channels using blockchain technology or systems.

The definition of a blockchain information service provider includes:

• the entity or node that provides the service to the public; and
• an institution or organization that supplies technical support to that service provider.

Applicants submit their details through the CAC’s Blockchain Information Service Filing Management System. Once accepted, the service receives a public filing number in the format 省/市网信备…号, such as 京网信备 for Beijing or 沪网信备 for Shanghai.

The filing records information about the provider and the specific blockchain service. It is not a general company-level approval covering every current or future blockchain product.

What Are the Key Points About Blockchain Information Service Filing?

• The filing applies to blockchain-based information services operating in mainland China and provided to the public.
• Service operators, blockchain nodes, and technical-support providers can fall within the definition of a provider.
• The statutory filing deadline is within 10 working days after the service begins operating.
• The CAC has 20 working days to process a complete submission, although preparation, questions, and remediation can extend the project timetable.
• A separate filing may be needed for each materially distinct blockchain service.
• The filing number must be displayed prominently on the relevant website, app, or service interface.
• Material filing information must be updated within five working days after a change.
• Service termination must be filed 30 working days in advance.
• Filing does not replace ICP, mobile app, public-security, cybersecurity, data, algorithm, or industry approvals.
• Filing does not legalize virtual-currency trading, token issuance, or another prohibited activity.
• The CAC can periodically verify filing information and inspect the provider’s compliance.

Which Blockchain Services Need to File?

The filing is relevant to public-facing services such as:

• blockchain-as-a-service, or BaaS, platforms;
• distributed-ledger infrastructure and blockchain nodes;
• blockchain evidence-preservation and electronic-certificate services;
• product provenance, anti-counterfeiting, and supply-chain traceability platforms;
• blockchain copyright registration and digital-rights platforms;
• trade, logistics, invoice, and supply-chain collaboration systems;
• blockchain identity and verifiable-credential services;
• blockchain-based data exchange and trusted-data platforms;
• financial, insurance, and asset-management applications using blockchain;
• public-service, judicial, notarial, or government blockchain platforms;
• digital-collection and digital-content platforms, where the underlying business model is otherwise lawful;
• blockchain wallets or blockchain browsers, subject to China’s restrictions on virtual-currency activity; and
• websites, mobile apps, mini-programs, or APIs that expose blockchain-based information services to users.

The product does not have to market itself as a “blockchain company.” A blockchain function embedded in a larger platform may still be in scope if it provides information services to the public.

The rules also expressly include institutions providing technical support to the service operator. A BaaS vendor, node operator, or blockchain technology provider should therefore assess its own filing position rather than assuming that only its customer is responsible.

Which Blockchain Systems May Fall Outside the Filing Scope?

A blockchain implementation is less likely to require filing when it is a genuinely internal technical system that does not provide information services to the public. Examples may include a permissioned ledger used only by one company’s employees for internal reconciliation or audit purposes.

However, the analysis becomes less clear when:

• external customers, suppliers, distributors, or institutions can access the system;
• a customer-facing website, app, API, or mini-program exposes blockchain records;
• several independent participants operate nodes;
• the platform provider supplies blockchain technology to third parties;
• public users can create, upload, verify, trade, or retrieve information; or
• the blockchain function is part of a broader regulated online service.

The official filing guide also allows an applicant to submit screenshots and workflow materials where a system cannot be accessed externally. Companies should therefore not treat an “internal system” label as an automatic exemption. The service architecture, participants, technical provider, and actual information flows should be reviewed with the relevant provincial CAC.

What Information and Documents Are Required?

The filing system separates the submission into information about the applicant, the responsible person, and the individual blockchain service.

A typical institutional filing package includes:

Applicant Information

• applicant name and organization type;
• province, city, and district;
• unified social credit code and registered address;
• investor or supervising organization;
• detailed correspondence address;
• website URL;
• business-licence or registration-certificate scan; and
• a signed and company-stamped declaration that the materials are authentic.

Responsible-Person Information

• name of the responsible person or legal representative;
• Chinese identity-document details and scans;
• office telephone number;
• mobile telephone number; and
• email address.

Service Information

• the exact blockchain service name;
• website homepage URL, app, mini-program, API, or other access point;
• service launch date;
• description of the service, users, functions, and application field;
• test credentials if access requires login;
• screenshots and a workflow explanation if the service is not publicly accessible;
• service-responsible-person details;
• the applicant’s role as infrastructure provider, application operator, or technical provider;
• blockchain platform, chain, node, or BaaS information;
• server IP addresses and deployment locations;
• user numbers, service objects, activity information, or other metrics requested for the relevant service type;
• on-chain account or smart-contract addresses where applicable;
• source-code, open-source, white-paper, or technical-document information where applicable; and
• information about customers or organizations receiving the technical service.

The system fields vary according to the service category. The original filing guide includes categories such as nodes, wallets, blockchain browsers, technical services, and BaaS. Those form categories do not make every listed activity lawful under current Chinese policy. The underlying product and business model must be assessed separately.

Applicants should check the live system and consult the competent provincial CAC before submission because form fields, evidentiary expectations, and local review practices can change.

What Product Controls Must Be Ready Before Filing?

The filing is tied to substantive operational responsibilities. Under the Blockchain Information Service Provisions, the provider should have controls covering:

• user registration and real-name authentication;
• information review and content governance;
• rapid handling of prohibited content;
• emergency response and incident escalation;
• technical and organizational security safeguards;
• public platform rules and user agreements;
• warnings, restrictions, account closure, and other user-management measures;
• complaint and reporting channels;
• personal-information and data protection;
• retention of user-published content and system logs for at least six months;
• lawful cooperation with regulator and law-enforcement requests; and
• monitoring and remediation of information-security risks.

Users who do not complete real-identity authentication must not be given access to the relevant blockchain information service. Authentication may be based on an organization code, identity-document number, mobile number, or another legally accepted method.

Because blockchain records can be difficult or impossible to alter, the company should decide before launch which information may be written on-chain. Personal information, confidential information, unlawful content, and data requiring deletion or correction create particular compliance problems when stored immutably.

How Do You Complete the Blockchain Information Service Filing?

A typical project follows these stages:

Stage 1: Assess the Service

Map the product, users, blockchain infrastructure, nodes, technical providers, public interfaces, on-chain data, and regulated functions. Confirm which entity or entities meet the definition of a provider.

Stage 2: Confirm the China Structure

Align the mainland applicant, domain, website or app operator, cloud account, server deployment, blockchain contract, privacy role, and customer agreements.

Stage 3: Prepare the Live Service and Policies

Implement real-name authentication, information controls, user rules, security measures, complaint channels, log retention, and incident-response processes. Prepare a working test account and supporting screenshots.

Stage 4: Create the Filing Account

Register through the official filing system. One filing applicant should use one account, even where that applicant operates several services.

Stage 5: Submit Applicant and Service Information

Complete the applicant, responsible-person, basic service, and detailed technical sections. A single applicant can submit separate filing applications for multiple blockchain services.

Stage 6: Respond to Review Questions

The provincial and national cyberspace authorities review the information. Incomplete or inconsistent materials may be returned with comments. The applicant should revise the filing and, where requested, provide additional documents or product access.

Stage 7: Receive and Display the Filing Number

Once filing is completed, the CAC issues a filing number and publishes the registered information. The provider must display the number prominently on the website, app, or other external service interface.

When Must the Filing Be Submitted and How Long Does It Take?

The regulations require a provider to submit its filing information within 10 working days after beginning to provide the service.

Where the submitted materials are complete, the CAC must complete filing and issue a filing number within 20 working days after receiving them. If the materials are incomplete, the authority must reject the filing and explain the reason within the same period.

These are statutory filing and review periods, not a guarantee that an entire compliance project will finish in 20 working days. Applicant restructuring, technical changes, document preparation, test access, local consultation, incomplete materials, and resubmission can extend the practical timeline.

Companies should prepare before launch even though the formal deadline runs from the start of service. Launching first without a filing-ready product creates a risk that the 10-working-day deadline will expire while the applicant is still addressing structural or technical problems.

There is no government application fee stated for the filing itself. The broader project may involve legal and technical assessment, China hosting, product localization, security testing, policy preparation, ICP or app filing, and other compliance costs.

Is a Separate Security Assessment Required?

Potentially. Article 9 of the Blockchain Information Service Provisions states that a provider launching a new product, application, or function must complete a security assessment in accordance with the applicable rules.

The CAC’s clarification on blockchain security assessments says that companies may commission an appropriately accredited assessment organization or conduct a self-assessment. Where the service falls within the security-assessment rules for internet information services with public-opinion attributes or social-mobilization capacity, the self-assessment report is submitted through the National Internet Security Management Service Platform.

The CAC also states that it has not designated or authorized any organization to perform blockchain security testing or assessments. A company should be cautious if a service provider claims to be an exclusive or officially appointed CAC assessment body.

The need, scope, and submission route should be assessed based on the product’s functions, users, content, and risks rather than assumed from the blockchain filing alone.

Does Blockchain Filing Replace ICP Filing or Other China Approvals?

No. Blockchain Information Service Filing addresses one aspect of CAC oversight. A service may need several parallel filings, licences, and security measures.

Requirement	Why it may apply
ICP Filing	A non-commercial website or online service is hosted in mainland China
Commercial ICP, EDI, IDC, or other telecom licence	The service carries out a regulated commercial value-added telecommunications activity
Mobile App Filing	The blockchain service is distributed as a mobile app in China
Public Security Bureau Filing	A mainland-hosted website is subject to public-security network registration
Cybersecurity classified protection	The information system requires classified cybersecurity protection measures
Personal information and data compliance	The service processes user identities, transactions, device information, logs, or other regulated data
Security assessment	A new product, application, or function triggers the applicable internet-information security-assessment rules
Algorithm or AIGC filing	The product also provides regulated recommendation, synthesis, or generative AI functions
Industry approval	The service operates in finance, news, publishing, healthcare, education, mapping, or another regulated field
Commercial cryptography compliance	The product uses commercial cryptography in a manner subject to China’s cryptography rules

For more detail on website requirements, see AppInChina’s complete guide to China’s ICP Filing.

Does Filing Make Cryptocurrency, Tokens, or Digital Assets Legal?

No. The CAC expressly states that blockchain filing is only a record of information supplied by the applicant. It is not recognition or approval of the company, product, or business.

China’s 2021 notice on virtual-currency transaction risks treats virtual-currency exchange, exchange between virtual currencies, token-issuance financing, virtual-currency derivatives, pricing and information intermediation for transactions, and related services as illegal financial activities. Overseas exchanges providing services to mainland residents are also covered by the restrictions.

A blockchain filing number therefore cannot be used to suggest that a token, exchange, wallet, digital collection, NFT, real-world-asset product, or investment arrangement has government approval. These products require a separate legal assessment of their issuance, trading, transfer, pricing, marketing, custody, payment, intellectual-property, and financial characteristics.

The CAC has specifically warned that a filing result must not be used for publicity or other promotional purposes. The number may be displayed as legally required, but it should not be presented as a regulatory endorsement.

Which Blockchain Services Have Already Completed Filing?

The CAC publishes domestic blockchain information service filing numbers in batches. As of August 2026, the latest published announcement is the 21st batch, released on 15 January 2026 and covering 64 services.

The published lists show that filing is used across a wide range of industries. Examples from the CAC’s 19th batch and other recent official lists include:

• China Postal Savings Bank blockchain systems for Xiong’an construction-fund management and small-business financial services;
• the National Archives of Publications and Culture’s digital-edition registration and trusted-certification platform;
• Geely Chain from Zhejiang Geely Holding Group;
• the Wuhan blockchain notarization service platform;
• copyright protection and electronic evidence-preservation services;
• product traceability, supply-chain, identity, and certificate platforms;
• blockchain BaaS and trusted-data services; and
• digital-content and digital-collection platforms.

These examples illustrate the scope of the system but do not amount to a CAC ranking or endorsement. A published filing confirms only that the named provider filed the named service under the Blockchain Information Service Provisions.

Companies and users can search public records through the official Blockchain Information Service Filing Management System.

What Must a Provider Do After Filing?

Filing creates continuing obligations. The provider should:

• display the filing number prominently;
• keep applicant, service, URL, app, server, node, and technical information accurate;
• report changes to service items or platform URLs within five working days;
• participate in periodic filing-information checks;
• maintain user real-name verification;
• keep user-published content and logs for at least six months;
• preserve information-security, content-management, and emergency controls;
• handle unlawful users and information promptly;
• maintain a public complaint and reporting channel;
• cooperate with CAC inspections and lawful requests;
• reassess new products, applications, functions, nodes, or technical providers; and
• submit cancellation 30 working days before terminating the service and make appropriate arrangements for users and data.

One filing number should not be treated as permanent coverage for a changing product. A new service, major function, operating entity, platform URL, chain, node structure, technical provider, or business model may require a filing change or a separate filing.

What Penalties Can Apply for Non-Compliance?

Failure to file or submission of false information can lead to an order to correct the violation. Refusal to correct, or a serious violation, can result in a warning and a fine of CNY 10,000 to CNY 30,000.

Other violations – including failures involving policies, technical controls, security assessment, filing changes, number display, log retention, complaints, or regulator cooperation – can result in a warning, an order to correct, suspension of the relevant service during remediation, and fines of CNY 5,000 to CNY 30,000.

Using the service to produce or distribute prohibited information can lead to suspension, remediation, and fines of CNY 20,000 to CNY 30,000. More serious conduct may also create liability under the Cybersecurity Law, data and privacy laws, financial rules, or criminal law.

The statutory fine is only one risk. A provider may also face service interruption, app-store or platform issues, regulator scrutiny, customer concerns, and difficulty completing related licences or commercial partnerships.

What Common Mistakes Delay Blockchain Filing?

Common problems include:

• assuming that any use of blockchain requires filing without first assessing the public-information-service trigger;
• assuming that a private or permissioned chain is automatically exempt;
• overlooking the filing position of a BaaS provider, node operator, or technical-support company;
• using an applicant that does not match the actual service operator;
• submitting a brand name that does not match the live product or contracts;
• failing to disclose all service URLs, apps, APIs, nodes, and deployment locations;
• providing no working test account, screenshots, or workflow documentation;
• describing a conceptual product that is inconsistent with the live service;
• launching before real-name authentication, user rules, content controls, complaints, and log retention are operational;
• storing personal information or unlawful content immutably on-chain;
• treating the 20-working-day review period as the full project timeline;
• believing the filing replaces ICP, app, cybersecurity, data, or sector approvals;
• using the filing number as a marketing endorsement; and
• assuming that filing makes a token, digital asset, or trading model lawful.

The best time to resolve these issues is before the company commits to its China entity, cloud architecture, blockchain provider, domain, app ownership, and launch date.

How Can AppInChina Help?

AppInChina helps foreign companies plan and implement a compliant route for blockchain platforms, websites, mobile apps, SaaS products, APIs, connected services, and enterprise technology in China.

Our support can include:

• assessing whether the service falls within the blockchain filing rules;
• identifying the provider, node, technical-support, and applicant responsibilities;
• structuring the China entity, hosting, domain, app, and operating arrangements;
• reviewing the blockchain, data, smart-contract, node, and service architecture;
• preparing the applicant and service filing materials;
• coordinating test access, screenshots, technical documents, and regulator questions;
• aligning real-name verification, user agreements, content controls, complaints, logs, and incident procedures;
• coordinating ICP, app, public-security, cybersecurity, algorithm, AIGC, and related work; and
• supporting filing changes, periodic checks, new services, and cancellation.

If your company plans to launch a blockchain-based service in China, contact us for a free initial compliance assessment to confirm what is needed for a smooth and compliant entry into the Chinese digital market.