ICP Registrations for Mobile Applications in China

0、Foreword

Recently, the Ministry of Industry and Information Technology issued the "Notice of the Ministry of Industry and Information Technology on Carrying out the Registration of Mobile Internet Applications", which is the so-called App Registration Notice posted online. Many people intentionally or unintentionally misinterpreted the notice , common mistakes** interpretation. The passage that has been seriously misread is:

Network access service providers, distribution platforms, and smart terminal manufacturers are not allowed to provide network access, distribution, preset and other services for APPs that have not completed the registration procedures. ¹

Common misinterpretations include:

1. App is about to usher in the era of whitelisting and whitelisting, and Quanzhou’s experience will be promoted nationwide.
2. Unregistered apps are not allowed to be installed or connected to the Internet in the future. This is a behavior preset in the system in conjunction with mobile phone manufacturers.

Next, I will refer to the "Interpretation of the "Notice of the Ministry of Industry and Information Technology on Carrying out the Registration of Mobile Internet Applications" ² to give you a more correct interpretation and refute the rumors that are spreading wildly on the Internet.

1. What is App registration?

App filing refers to the process in which mobile Internet application (App) organizers file and register with the industry and information technology departments in accordance with the requirements of relevant laws and regulations.

According to the "Anti-Telecommunications Network Fraud Law of the People's Republic of China", "Internet Information Services Management Measures" and other regulations, App sponsors engaged in Internet information services need to complete the filing procedures, obtain a filing number, and clearly indicate the filing number and The website address of the filing system is available for public inquiry and verification.

The purpose of registration is to regulate the mobile Internet industry, protect the legitimate rights and interests of citizens and organizations, and safeguard network security and public interests.

Provincial version: Just like website ICP filing, doing business in mainland China requires filing. Registration is not mandatory, but you cannot conduct business in mainland China without registration.

What is the impact: Refer to the website ICP filing, there is basically no impact.

2. What will happen if the App is not registered?

Read the original text first:

(1) APP sponsors engaged in Internet information services within the territory of the People’s Republic of China shall perform registration procedures in accordance with the Anti-Telecommunications Network Fraud Law of the People’s Republic of China, the Measures for the Administration of Internet Information Services (State Council Order No. 292), and other regulations, Those who fail to complete the filing procedures are not allowed to engage in APP Internet information services.
(2) The Ministry of Industry and Information Technology supervises and guides the national APP registration work, and the communications administration bureaus of provinces, autonomous regions, and municipalities directly under the Central Government are responsible for the implementation and supervision of APP registration management.
(3) The domain name, IP address and other network resources used by the APP sponsor shall comply with the "Internet Domain Name Management Measures" (Ministry of Industry and Information Technology Order No. 43) and the "Internet IP Address Registration Management Measures" (former Ministry of Information Industry Order No. 43) 34) "Notice of the Ministry of Industry and Information Technology on Regulating the Use of Domain Names for Internet Information Services" (Ministry of Industry and Information Technology Information Management [2017] No. 264) and other management requirements.
(4) APP sponsors should truthfully fill in the "Internet Information Service Registration Form" (hereinafter referred to as the "Registration Form") and relevant commitment letters.
Sponsors of APP Internet information services such as news, publishing, education, film and television, religion, etc., when performing registration procedures, should also submit documents for review and approval by the relevant competent authorities to the provincial communications bureau where they are domiciled.
The telecommunications authorities may adjust the contents of the "Registration Form" and relevant commitment letters based on the actual situation.
(5) The APP sponsor shall complete the filing procedures with the provincial communications administration bureau where it is domiciled, and its network access service provider and APP distribution platform (hereinafter referred to as the distribution platform) shall pass the "National Internet Basic Resource Management System" (i.e. The ICP/IP address/domain name information filing management system (hereinafter referred to as the filing system) adopts the method of online application submission and inspection and review.
(6) Network access service providers and distribution platforms should verify the real identities, network resources and other information of users of organizations or individuals planning to engage in APP Internet information services, and shall not act on their behalf when they know or should know that the information is inaccurate. Complete the filing procedures.
(7) After receiving the filing materials submitted by the APP sponsor, the provincial communications bureau shall, if the materials are complete and accurate, file them within twenty working days, issue a filing number to them, and report them to the public through the filing system Publish the filing information; if the materials are incomplete or inaccurate, they will not be filed and the reasons will be explained.
(8) The APP sponsor shall indicate its registration number in a prominent position on the APP, and link to the registration system URL as required below the registration number for public inquiry and verification. The distribution platform should indicate the registration number information of the APPs it distributes in a conspicuous position, and report the relevant information of the distributed APPs to the telecommunications authority.
If the APP information changes, cancels, etc., the APP sponsor shall complete the change, cancellation and other procedures with the original filing authority.
(9) Network access service providers, distribution platforms, and smart terminal manufacturers shall not provide network access, distribution, preset and other services for APPs that have not completed the registration procedures.
(10) APP sponsors, network access service providers, distribution platforms, and smart terminal manufacturers should establish and improve mechanisms for monitoring and handling illegal and illegal information. If they discover information that is prohibited from being released or transmitted by laws and administrative regulations, they should immediately stop transmitting the information. Information, take disposal measures such as elimination to prevent the spread of information, keep relevant records, report to the telecommunications authorities, and dispose according to the requirements of the telecommunications authorities.

Let’s look at the interpretation:

Network access service providers, application distribution platforms, and smart terminal manufacturers are not allowed to provide network access, distribution, preset and other services for APPs that have not completed the registration procedures.
APP sponsors, network access service providers, application distribution platforms, and smart terminal manufacturers should establish and improve mechanisms for monitoring and handling illegal and illegal information. If they discover information that is prohibited from being released or transmitted by laws and administrative regulations, they should immediately stop transmitting the information. Take disposal measures such as elimination to prevent the spread of information, keep relevant records, report to the telecommunications authorities, and dispose according to the requirements of the telecommunications authorities.

Provincial streaming version: Apps that are not registered are not allowed to use servers in mainland China to provide data transmission services, and service providers (that is, cloud vendors) are not allowed to provide servers in mainland China to apps that are not registered.

What is the impact: Unregistered apps can no longer use servers in mainland China. After registration, data transmission will be strictly supervised, and if any illegal or illegal content is found, it will be dealt with in accordance with the law.

3. When will it take effect?

Read the original text first:

(1) Work preparation stage (before the end of August 2023). The communications bureaus of each province, autonomous region, and municipality directly under the Central Government organize APP sponsors, network access service providers, distribution platforms, etc. within their jurisdiction to clarify management requirements and formulate implementation plans to ensure the steady progress of relevant work. Network access service providers and distribution platforms should, in accordance with the requirements, build and upgrade the enterprise-side filing system, complete the docking test with the ministry-side filing system, and have functions such as reporting and verification of APP information.
(2) Existing APP registration stage (September 2023-March 2024). APPs that have started business before the issuance of this notice should, in accordance with the requirements of this notice, complete the filing procedures with the provincial communications bureau where they are domiciled through their network access service providers and distribution platforms. Among them, those who have completed the website registration procedures only need to supplement and complete the relevant information of their APP, and do not need to repeatedly fill in the true identity information of the organizer. If there is no website registration information, the registration procedures shall be carried out in accordance with the provisions of this notice.

APPs that plan to carry out business after the issuance of this notice should first complete the filing procedures in accordance with the requirements of this notice before starting business.

(3) Supervision and inspection stage (April 2024-June 2024). The Ministry of Industry and Information Technology organizes APP registration inspections, and the communications administration bureaus of all provinces, autonomous regions, and municipalities directly urge relevant units to fill in, supplement, and update APP registration information in a timely manner, and provide access to network access service providers, distribution platforms, and smart terminal manufacturers. , distributed, and pre-installed APPs are inspected. For APPs that fail to perform the filing procedures and engage in illegal activities, the communications bureaus of all provinces, autonomous regions, and municipalities directly under the Central Government should deal with them in accordance with relevant laws and regulations.
(4) Normalization work stage (July 2024 to long-term). The communications bureaus of all provinces, autonomous regions, and municipalities directly under the Central Government regularly organize network access service providers, distribution platforms, and intelligent terminal manufacturers to conduct assessments on the accuracy of APP registration information, take effective technical measures to strengthen APP compliance management, and improve the level of mobile Internet supervision.

Interpretation:

Taking into account the actual business conditions of APP sponsors, network access service providers, application distribution platforms, and smart terminal manufacturers, the "Notice" has reserved 10 months as a transition period for APP registration work.
From September 2023 to the end of March 2024, APPs that started business before the issuance of the "Notice" will complete the registration procedures with the provincial communications administration bureau where they are domiciled. From April 2024 to the end of June 2024, the telecommunications authorities will organize supervision and inspection of APP registration status, and deal with APPs that have not completed the registration procedures in accordance with the law.
Apps that plan to start business after the "Notice" is issued should first complete the filing procedures before starting business.

Stream-saving version: Existing apps must complete the registration within 10 months (before the end of March 2024), and supervision and inspection will begin from April to June 2024. New apps need to be registered before being put on the shelves and providing services.

What is the impact: For existing apps, developers need to go through the procedures as soon as possible or stop the app business in mainland China and migrate the servers to areas outside mainland China; new apps need to be registered when they are launched in mainland China.

4. Summary

To sum up, this notice can be summarized as follows:

The Ministry of Industry and Information Technology emphasizes that mobile application registration is to regulate the Internet application market and protect the rights and interests of users, rather than restricting innovation and development.
The filing requirements are mainly to ensure the security and legality of applications, protect user privacy, and prevent illegal activities.
At the same time, the Ministry of Industry and Information Technology also encourages innovation and development and supports the promotion and use of high-quality applications. Therefore, it is necessary and beneficial for mobile app developers and users to comply with filing requirements.

Or:

1. Unregistered Apps on your mobile phone will not be unavailable; installation packages of unregistered Apps will not be blocked from installation;
2. The relevant statement "not allowed to provide network services" means that cloud vendors are not allowed to provide servers for unregistered apps to use. It does not mean that mobile phone manufacturers are not allowed to allow unregistered apps to connect to the Internet.

All in all, this is a continuation of the website ICP registration policy in the field of mobile software, not an expansion of the "Quanzhou experience". At least for now, whitelists will not become popular that quickly.

Recently, the Ministry of Industry and Information Technology issued the "Notice of the Ministry of Industry and Information Technology on Carrying out the Registration of Mobile Internet Applications", which is the so-called App Registration Notice posted online. Many people intentionally or unintentionally misinterpreted the notice , common mistakes** interpretation. The passage that has been seriously misread is:

Network access service providers, distribution platforms, and smart terminal manufacturers are not allowed to provide network access, distribution, preset and other services for APPs that have not completed the registration procedures. ³

Common misinterpretations include:

1. App is about to usher in the era of whitelisting and whitelisting, and Quanzhou’s experience will be promoted nationwide.
2. Unregistered apps are not allowed to be installed or connected to the Internet in the future. This is a behavior preset in the system in conjunction with mobile phone manufacturers.

Next, I will refer to the "Interpretation of the "Notice of the Ministry of Industry and Information Technology on Carrying out the Registration of Mobile Internet Applications" ⁴ to give you a more correct interpretation and refute the rumors that are spreading wildly on the Internet.

1. What is App registration?

App filing refers to the process in which mobile Internet application (App) organizers file and register with the industry and information technology departments in accordance with the requirements of relevant laws and regulations.

According to the "Anti-Telecommunications Network Fraud Law of the People's Republic of China", "Internet Information Services Management Measures" and other regulations, App sponsors engaged in Internet information services need to complete the filing procedures, obtain a filing number, and clearly indicate the filing number and The website address of the filing system is available for public inquiry and verification.

The purpose of registration is to regulate the mobile Internet industry, protect the legitimate rights and interests of citizens and organizations, and safeguard network security and public interests.

Provincial version: Just like website ICP filing, doing business in mainland China requires filing. Registration is not mandatory, but you cannot conduct business in mainland China without registration.

What is the impact: Refer to the website ICP filing, there is basically no impact.

2. What will happen if the App is not registered?

Read the original text first:

(1) APP sponsors engaged in Internet information services within the territory of the People’s Republic of China shall perform registration procedures in accordance with the Anti-Telecommunications Network Fraud Law of the People’s Republic of China, the Measures for the Administration of Internet Information Services (State Council Order No. 292), and other regulations, Those who fail to complete the filing procedures are not allowed to engage in APP Internet information services.
(2) The Ministry of Industry and Information Technology supervises and guides the national APP registration work, and the communications administration bureaus of provinces, autonomous regions, and municipalities directly under the Central Government are responsible for the implementation and supervision of APP registration management.
(3) The domain name, IP address and other network resources used by the APP sponsor shall comply with the "Internet Domain Name Management Measures" (Ministry of Industry and Information Technology Order No. 43) and the "Internet IP Address Registration Management Measures" (former Ministry of Information Industry Order No. 43) 34) "Notice of the Ministry of Industry and Information Technology on Regulating the Use of Domain Names for Internet Information Services" (Ministry of Industry and Information Technology Information Management [2017] No. 264) and other management requirements.
(4) APP sponsors should truthfully fill in the "Internet Information Service Registration Form" (hereinafter referred to as the "Registration Form") and relevant commitment letters.
Sponsors of APP Internet information services such as news, publishing, education, film and television, religion, etc., when performing registration procedures, should also submit documents for review and approval by the relevant competent authorities to the provincial communications bureau where they are domiciled.
The telecommunications authorities may adjust the contents of the "Registration Form" and relevant commitment letters based on the actual situation.
(5) The APP sponsor shall complete the filing procedures with the provincial communications administration bureau where it is domiciled, and its network access service provider and APP distribution platform (hereinafter referred to as the distribution platform) shall pass the "National Internet Basic Resource Management System" (i.e. The ICP/IP address/domain name information filing management system (hereinafter referred to as the filing system) adopts the method of online application submission and inspection and review.
(6) Network access services
Providers and distribution platforms should verify the real identities, network resources and other information of users of organizations or individuals planning to engage in APP Internet information services, and shall not perform registration procedures on their behalf when they know or should know that the information is inaccurate.
(7) After receiving the filing materials submitted by the APP sponsor, the provincial communications bureau shall, if the materials are complete and accurate, file them within twenty working days, issue a filing number to them, and report them to the public through the filing system Publish the filing information; if the materials are incomplete or inaccurate, they will not be filed and the reasons will be explained.
(8) The APP sponsor shall indicate its registration number in a prominent position on the APP, and link to the registration system URL as required below the registration number for public inquiry and verification. The distribution platform should indicate the registration number information of the APPs it distributes in a conspicuous position, and report the relevant information of the distributed APPs to the telecommunications authority.
If the APP information changes, cancels, etc., the APP sponsor shall complete the change, cancellation and other procedures with the original filing authority.
(9) Network access service providers, distribution platforms, and smart terminal manufacturers shall not provide network access, distribution, preset and other services for APPs that have not completed the registration procedures.
(10) APP sponsors, network access service providers, distribution platforms, and smart terminal manufacturers should establish and improve mechanisms for monitoring and handling illegal and illegal information. If they discover information that is prohibited from being released or transmitted by laws and administrative regulations, they should immediately stop transmitting the information. Information, take disposal measures such as elimination to prevent the spread of information, keep relevant records, report to the telecommunications authorities, and dispose according to the requirements of the telecommunications authorities.

Let’s look at the interpretation:

Network access service providers, application distribution platforms, and smart terminal manufacturers are not allowed to provide network access, distribution, preset and other services for APPs that have not completed the registration procedures.
APP sponsors, network access service providers, application distribution platforms, and smart terminal manufacturers should establish and improve mechanisms for monitoring and handling illegal and illegal information. If they discover information that is prohibited from being released or transmitted by laws and administrative regulations, they should immediately stop transmitting the information. Take disposal measures such as elimination to prevent the spread of information, keep relevant records, report to the telecommunications authorities, and dispose according to the requirements of the telecommunications authorities.

Provincial streaming version: Apps that are not registered are not allowed to use servers in mainland China to provide data transmission services, and service providers (that is, cloud vendors) are not allowed to provide servers in mainland China to apps that are not registered.

What is the impact: Unregistered apps can no longer use servers in mainland China. After registration, data transmission will be strictly supervised, and if any illegal or illegal content is found, it will be dealt with in accordance with the law.

3. When will it take effect?

Read the original text first:

(1) Work preparation stage (before the end of August 2023). The communications bureaus of each province, autonomous region, and municipality directly under the Central Government organize APP sponsors, network access service providers, distribution platforms, etc. within their jurisdiction to clarify management requirements and formulate implementation plans to ensure the steady progress of relevant work. Network access service providers and distribution platforms should, in accordance with the requirements, build and upgrade the enterprise-side filing system, complete the docking test with the ministry-side filing system, and have functions such as reporting and verification of APP information.
(2) Existing APP registration stage (September 2023-March 2024). APPs that have started business before the issuance of this notice should, in accordance with the requirements of this notice, complete the filing procedures with the provincial communications bureau where they are domiciled through their network access service providers and distribution platforms. Among them, those who have completed the website registration procedures only need to supplement and complete the relevant information of their APP, and do not need to repeatedly fill in the true identity information of the organizer. If there is no website registration information, the registration procedures shall be carried out in accordance with the provisions of this notice.

APPs that plan to carry out business after the issuance of this notice should first complete the filing procedures in accordance with the requirements of this notice before starting business.

(3) Supervision and inspection stage (April 2024-June 2024). The Ministry of Industry and Information Technology organizes APP registration inspections, and the communications administration bureaus of all provinces, autonomous regions, and municipalities directly urge relevant units to fill in, supplement, and update APP registration information in a timely manner, and provide access to network access service providers, distribution platforms, and smart terminal manufacturers. , distributed, and pre-installed APPs are inspected. For APPs that fail to perform the filing procedures and engage in illegal activities, the communications bureaus of all provinces, autonomous regions, and municipalities directly under the Central Government should deal with them in accordance with relevant laws and regulations.
(4) Normalization work stage (July 2024 to long-term). The communications bureaus of all provinces, autonomous regions, and municipalities directly under the Central Government regularly organize network access service providers, distribution platforms, and intelligent terminal manufacturers to conduct assessments on the accuracy of APP registration information, take effective technical measures to strengthen APP compliance management, and improve the level of mobile Internet supervision.

Interpretation:

Taking into account the actual business conditions of APP sponsors, network access service providers, application distribution platforms, and smart terminal manufacturers, the "Notice" has reserved 10 months as a transition period for APP registration work.
From September 2023 to the end of March 2024, APPs that started business before the issuance of the "Notice" will complete the registration procedures with the provincial communications administration bureau where they are domiciled. From April 2024 to the end of June 2024, the telecommunications authorities will organize supervision and inspection of APP registration status, and deal with APPs that have not completed the registration procedures in accordance with the law.
Apps that plan to start business after the "Notice" is issued should first complete the filing procedures before starting business.

Stream-saving version: Existing apps must complete the registration within 10 months (before the end of March 2024), and supervision and inspection will begin from April to June 2024. New apps need to be registered before being put on the shelves and providing services.

What is the impact: For existing apps, developers need to go through the procedures as soon as possible or stop the app business in mainland China and migrate the servers to areas outside mainland China; new apps need to be registered when they are launched in mainland China.

4. Summary

To sum up, this notice can be summarized as follows:

The Ministry of Industry and Information Technology emphasizes that mobile application registration is to regulate the Internet application market and protect the rights and interests of users, rather than restricting innovation and development.
The filing requirements are mainly to ensure the security and legality of applications, protect user privacy, and prevent illegal activities.
At the same time, the Ministry of Industry and Information Technology also encourages innovation and development and supports the promotion and use of high-quality applications. Therefore, it is necessary and beneficial for mobile app developers and users to comply with filing requirements.

Or:

1. Unregistered Apps on your mobile phone will not be unavailable; installation packages of unregistered Apps will not be blocked from installation;
2. The relevant statement "not allowed to provide network services" means that cloud vendors are not allowed to provide servers for unregistered apps to use. It does not mean that mobile phone manufacturers are not allowed to allow unregistered apps to connect to the Internet.

All in all, this is a continuation of the website ICP registration policy in the field of mobile software, not an expansion of the "Quanzhou experience". At least for now, whitelists will not become popular that quickly.