How To Obtain China’s ICP Filing and ICP License

Foreign companies entering China often hear about the ICP Filing and the ICP License. There are both commonly misnomered and mistaken for one another, leading to confusion and a lack of clarity when it comes to operating in compliance with local laws and regulations. 

This guide clarifies exactly what the ICP Filing and Commercial ICP License are, when you need the Filing, License, or both, and how foreign companies can obtain both without a Chinese entity. 

What is China’s ICP Filing?

The ICP Filing (Internet Content Provider Filing), commonly referred to as the ICP License, ICP 备案, or ICP Recordal is a mandatory filing for all websites, apps or Mini Programs hosted on servers in Mainland China established under Article 4 of the Administrative Measures on Internet-based Information Services (互联网信息服务管理办法)

China’s ICP Filing applies to :

• Any domain using Mainland China hosting (including informational websites, marketing websites, documentation portals).
• Non-commercial apps and Mini Programs.

According to estimates from the Chinese Internet Network Information Centre’s (CNNIC) 55th Statistical Report on China’s Internet Development, there are approximately 9,000,000 ICP Filed domains, apps, and Mini Programs in China. It’s administered at the provincial level on a per-domain basis, meaning you need a separate filing for each top-level domain you operate.

Filing numbers follow the format 京ICP备12345678号, where the first character indicates the issuing province. Your ICP Filing number must be displayed prominently in your website footer with a working link to the MIIT verification database.

How Do I Get an ICP Filing?

1. Establish a Chinese Entity or Work with a Local Partner. Obtaining a Mainland China domain and opening a Chinese cloud provider account requires a Chinese Business License (营业执照). Without this, you cannot complete the ICP Filing.  AppInChina helps foreign companies meet this requirement without setting up their own entity. 
2. Open a Chinese Cloud Provider account. ICP Filings must be tied to domains hosted on  Mainland China servers, so you’ll need a China-region account with providers such as such as AWS China, Azure China, Alibaba Cloud China or Tencent Cloud.
3. Submit Documentation Through Cloud Provider. Cloud providers help submit ICP Filing documentation to the Ministry of Industry and Information Technology (MIIT) for review and approval. 
4. Obtain ICP Filing number. Once approved, you receive an ICP Filing number for your registered domain. 
5. File for PSB Filing. Within 30 days of receiving the ICP Filing number, you must file for a Public Security Bureau (PSB) Filing.
6. Display ICP Filing number. The final step is to ensure that the ICP Filing and PSB Filing number are both displayed in the footer of the registered domain. 

For detailed guidance on the filing process, requirements, and timelines, see our complete guide to China’s ICP Filing.

What is China’s Commercial ICP License? 

The Commercial ICP License, commonly referred to as the ICP License or B25 License, is a mandatory commercial operating license required for businesses that provide paid internet information services in Mainland China. 

China’s Commercial ICP License applies to: 

• SaaS platforms 
• E-commerce websites
• Marketplaces and multi-vendor platforms
• Games with in-app purchases or advertising
• Monetised apps
• Ad-funded content platforms.

Commercial ICP License numbers follow the format 京ICP证12345678号, where “证” (certificate) replaces “备” (filing).The license is issued at the company level, but you still need individual ICP Filings for each domain/app you operate under that license. Many commercial operations need both: a company license and filings per domain/app.

How Do I Get the Commercial ICP License?

1. Establish a Chinese Entity or Work with a Local Partner. The Commercial ICP License requires a Chinese Business License holder with minimum registered capital (RMB 1 million for provincial operations, RMB 10 million for cross-regional). AppInChina helps foreign companies meet this requirement.
2. Prepare Required Documentation. Gather business licenses, legal representative identification, shareholder information, designated responsible personnel details, and personnel verification through social insurance certificates.
3. Submit Application to Provincial Communications Bureau. Applications are submitted to the communications administration bureau in the province where your business is registered for review and approval.
4. Technical Review and Assessment. Authorities conduct technical capability evaluations, security audits, and business model reviews.
5. Obtain Commercial ICP License number. Once approved, you will receive a Commercial ICP License number for your business entity.
6. Display Commercial ICP License number. The final step is to ensure that the Commercial ICP License number is displayed in the footer of all websites and apps operating under the license.

For comprehensive details on license requirements, application process, and compliance obligations, see our complete guide to China’s ICP License (B25).

What’s the Difference Between the ICP Filing and the ICP License?

The distinction comes down to commercial activity. The ICP Filing addresses where your content is hosted, while the Commercial ICP License addresses whether you generate revenue from that content.

	ICP Filing (备案)	Commercial ICP License (ICP许可证 / B25)
Purpose	Permission to host in Mainland China	Permission to operate commercial services
Applied To	Per domain/app	Per company
Typical Use Cases	Informational sites, corporate sites, non-commercial apps	SaaS, e-commerce, marketplaces, monetized apps/games
Who Needs It	Anyone hosting in Mainland China	Anyone conducting commercial online business
Entity Requirements	Must have Chinese entity or partner	Must have Chinese entity or partner
Processing Time	20 business days average	60-90 business days
Detailed Information	ICP Filing Guide	Commercial ICP License Guide

Do I Need an ICP Filing or ICP License?

The requirements vary significantly based on what your website, app, or platform actually does. Below are some common cases: 

Corporate or Marketing Website Only

• If your website is hosted in Mainland China and is purely informational, you typically only need an ICP Filing.
• This covers corporate sites, marketing pages, and documentation hubs that don’t involve transactions, user-generated content, or monetisation. However, you still need this filing to host in China and achieve optimal performance.

Paid SaaS or B2B Platform

• Subscription software, paid dashboard access, B2B service platforms, and analytics tools require both ICP Filing and Commercial ICP License.
• Any platform where users pay for access or features requires a Commercial ICP License, even in B2B contexts. The subscription itself triggers the commercial requirement as information is provided behind a paywall.

E-commerce or Online Booking Platform

• Online stores, booking portals, paid membership sites, and ticketing platforms require ICP Filing and Commercial ICP License.
• E-commerce operations involving payment processing require a Commercial ICP License whether you’re selling physical goods, services, or access to content. Additional licenses may be required depending on what you’re selling (e.g., food, pharmaceuticals, publishing).

Marketplace or Multi-Vendor Platform

• Multi-vendor marketplaces, aggregator platforms, commission-based services, and platform-as-a-service offerings require ICP Filing + Commercial ICP License, plus possible additional licenses.
• Platforms that enable third-party transactions typically require a Commercial ICP License. The fact that you’re facilitating commerce rather than conducting it directly doesn’t exempt you.

Mobile App or Game with Monetisation

• Apps with subscriptions, games with in-app purchases, and ad-monetised applications require a Mobile App ICP Filing and Commercial ICP License.
• Mobile apps and games that generate revenue through purchases or advertising require a Commercial ICP License. Non-monetised utility apps may only require a filing, but even ad revenue can trigger license requirements.

Content, Community, or Media Platform

• Forums, social platforms, streaming services, and ad-funded media sites require ICP Filing and Commercial ICP License.
• Platforms involving user-generated content, community features, or media distribution require a Commercial ICP License. Content platforms often trigger additional licensing requirements for publishing, audio/visual content, or live streaming due to the combination of commercial operation and content distribution.

What If You Don’t Have a Chinese Company?

Here’s where many foreign companies hit a roadblock: both ICP Filing and Commercial ICP License require a Chinese business entity. Foreign companies without a local presence cannot apply directly. As a foreign company, you have two options:

1. Establish a Chinese Subsidiary. With a Chinese subsidiary, you can apply for the ICP Filing and Commercial ICP License under your own entity. However, opening a local entity requires significant investment and ongoing management.
2. Work with a Local Partner. Working with a local partner allows you to meet the Chinese business entity requirement without establishing a Chinese subsidiary. Local partners such as AppInChina help companies obtain the ICP Filing for their website, app, or platform. AppInChina also allows companies to publish their solution under our Chinese entity which already has the Commercial ICP License.

Frequently Asked Questions

Can You Avoid ICP Requirements by Hosting Outside Mainland China?

Yes. Technically, ICP requirements only apply to infrastructure hosted within Mainland China’s. If you host in Hong Kong, Singapore, or elsewhere, you’re not legally required to obtain ICP permits.

However, there are both compliance and technical risks when it comes to hosting outside Mainland China. Websites that do not have an ICP Filing and are hosted outside China can experience:

• Significantly slower loading times due to the Great Firewall, with the potential of being blocked.
• Poor SEO performance on Baidu
• Compliance issues if actively targeting Chinese users

Do You Always Need Both the ICP Filing and a Commercial ICP License?

No. Many businesses only need an ICP Filing if your website is purely informational (corporate site, documentation, marketing pages), you’re not conducting transactions or monetising users, or you’re not running a platform or marketplace.

However, you need both if users pay for products, services, or access, you operate a marketplace or platform, you monetise through advertising, or you provide SaaS or subscription services. The commercial threshold is lower than many assume. When in doubt, consult with experts who understand current enforcement patterns.

Do I Need a Commercial ICP License If I Show Prices On My Website But Don’t Process Payments There?

This is a common gray area. The key question is whether you’re conducting commercial internet information services in China, not just where payment processing occurs.

If your Chinese website or app displays products with prices and enables purchasing (even if checkout happens on a third-party processor or offshore), you’re likely operating a commercial service requiring a license. The authorities focus on the user experience and business model, not the technical payment flow.

Does an English-only Website or App in China Still Need and ICP Filing or Commercial ICP License?

Yes. The language of your content doesn’t change ICP obligations. If your website, app, or platform is hosted on infrastructure in Mainland China, OR actively targets Chinese users (even in English), then ICP requirements apply regardless of language.

Many international companies maintain English-language sites in China for expatriate communities, international business users, or English-speaking Chinese users. These still technically require appropriate ICP permits.

How Can AppInChina Help?

Navigating China’s ICP requirements demands specialised expertise and a local entity. 

AppInChina can help with:

• Compliance Assessment. We provide a free assessment of your solution to determine which licenses you require, which may include the Commercial ICP License and other licenses, filings and certificates. Based on this we will confirm what options are available to you.

• Publishing. AppInChina already holds the Commercial ICP License, meaning we can publish your solution under our Chinese entity to bypass the licensing requirement for your business.

• License Application. If you’re trying to obtain the Commercial ICP License for your Chinese subsidiary in China, we can advise you on this complex application process.

Contact us to book an initial call and begin your compliant entry into the Chinese market.