How To Obtain China’s ICP Filing and ICP License

Foreign companies entering China are often told they need an ICP License, but in practice, there are two very different approvals that get lumped under that name, and the two are routinely confused.

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 You Need ICP Filing or a Commercial ICP License?

The fastest way to understand your requirement is to look at what your website, app, or platform does.

Business Scenario	ICP Filing Needed?	Commercial ICP License Needed?
Corporate website hosted in Mainland China	Yes	Usually no
Marketing website with no payments or transactions	Yes	Usually no
SaaS platform with paid subscriptions	Yes	Usually yes
E-commerce website	Yes	Usually yes
Marketplace or multi-vendor platform	Yes	Usually yes
Mobile app with paid features	Usually yes; Mobile App Filing may also apply	Usually yes
Game with in-app purchases or ads	Usually yes; game approval may also apply	Usually yes
Ad-supported content platform	Yes	Usually yes
Website hosted outside Mainland China	Usually no	Usually no, but performance and compliance risks remain

If your service is purely informational and hosted in Mainland China, ICP Filing may be enough. If your service generates revenue online, you should assess whether a Commercial ICP License is also required.

Can Foreign Companies Get an ICP License in China?

Foreign companies cannot usually apply for ICP Filing or a Commercial ICP License directly using only an overseas company registration. Both approvals normally require a Chinese business license.

Foreign companies generally have two options:

1. Establish a Chinese Subsidiary

A foreign company can establish a Chinese subsidiary, such as a WFOE, and apply for ICP Filing or Commercial ICP License under that Chinese entity. This gives the company direct control, but it requires company registration, accounting, tax management, local administration, and ongoing compliance work.

2. Work with a Local Partner

Foreign companies without a Chinese entity can work with a local partner such as AppInChina. This allows the company to meet the Chinese entity requirement without immediately establishing its own Chinese subsidiary.

For companies that want to launch quickly, working with a local partner is often the faster practical route. For companies with a long-term China strategy and significant local operations, establishing a Chinese subsidiary may be more appropriate.

What ICP Filing and ICP License Do Not Solve

Getting ICP approval is a compliance milestone, not a performance or legal catch-all. In particular, ICP approval does not automatically resolve:

• Blocked third-party resources. If your site loads fonts, scripts, analytics, maps, or CDNs from services blocked in China (for example, Google Fonts, Google Analytics, YouTube, Facebook SDKs), those resources will still fail inside mainland China even with a valid ICP Filing. You need to audit and replace them independently.
• Poor website performance in China. An ICP Filing lets you host in China, which is the precondition for good performance — but it does not guarantee it. Speed still depends on your architecture, CDN setup, image optimisation, and backend location.
• Offshore hosting issues. ICP approval applies to mainland-hosted services. If you choose to host in Hong Kong, Singapore, or elsewhere, ICP does not change the fact that your traffic still routes across the Great Firewall, with the latency and reliability issues that come with it.
• Broader legal and operational compliance. ICP approvals sit within a wider China compliance stack. Depending on your sector, you may also need PSB Filing, data compliance under PIPL, cybersecurity review, cross-border data transfer approvals, real-name verification, content moderation systems, and category-specific licenses (publishing, audio/visual, payments, health, education, etc.).

Both the ICP License and Filing are baselines to enter the Chinese internet.

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.