New regulation in China for Apps ICP-filling



In order to crack down on telecom and online fraud crimes, the Ministry of Industry and Information Technology (MIIT) of China issued a circular on July 21, 2023, requiring App developers who engaged in the provision of internet-based information services within the territory of China to carry out the ICP-filing procedures. Failure to do so will result in the App developer being prohibited from providing such services. The App developer shall carry out ICP-filling procedures with the provincial communications administrations of the places where they are domiciled. Their Internet Data Centre (IDC) service providers shall file an application and conduct verification and review online through the National Internet Basic Resource Management System.

In accordance with the circular's requirements, the App developers must provide accurate information during the ICP-filling procedures, which includes ICP-filling subject information, App basic information, App feature information, and App access information. Additionally, the App developers must display the filing number prominently in areas such as "settings" or "introduction" within the App. With regard to the timeline, Apps that have already launched on shelf prior to the issuance of the circular must carry out the ICP-filling procedure before April 2024. Apps that intend to launch after the issuance of the circular shall first carry out ICP-filing procedure before launch.

According to the circular, internet access service providers and application distributors are obligated not to provide relevant services and distribution for the applications without ICP-filing recordal number. Most foreign applications supplied to the Chinese market are distributed through app store. Apple Developer has recently updated their app store notice for CN store requiring the ICP-filing for the applications on shelf. 

If you are the app developer, we kindly recommend that you give greater attention to the circular issued by the MIIT, and promptly carry out the ICP-filling procedure. We are more than happy to provide assistance over the issue.

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Yue Liu
Attorney at Law | Trademark Agent
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