Foreign companies attempting to publish their apps or games on the Chinese market must comply with two new requirements.
The first is that two more major Chinese app stores are now requiring an ICP filing for all apps to be listed on their store.
As we previously reported back in October, the Baidu app store began requiring ICP Filings for all apps on its store. Now, two more major Chinese app stores are doing the same: Xiaomi and 360.
This stems from a 2017 government regulation, so we expect that eventually all app stores will follow suit in tightening up their compliance, making an ICP Filing a necessity for any app or game to be listed on any Chinese app stores.
If you are a developer who already has published an app on any of these three stores, you will be unable to update your app until this new requirement is met.
ICP stands for “Internet Content Provider”, and an ICP Filing should not be confused with an ICP License (also called ICP Commercial), which is a separate permit.
ICP Filings were originally needed to host informational websites, but are expanding to become a basic requirement for platforms, apps and games as well. Because ICP Filings are associated with a particular domain, this means you will also need a Chinese domain name and a functioning website for your app or game.
An ICP Filing application is not particularly complicated, difficult, or time-consuming. But it does need to be completed in Mandarin, and adds additional hurdles to an already labor-intensive bureaucratic process.
As an example, here are the additional materials needed for approval on the Baidu app store with the new requirement:
This is in addition to all the other materials currently required to apply for publication on a Chinese app store.
Second, we are learning that regulators reviewing game license applications will do an online search to see if the game under review is currently available for download in any Chinese app stores online. If it is, they are likely to reject the application.
For Android games, this is problematic. There are over 400 Chinese app stores, and many are little more than content aggregators that scrape the bigger app stores (such as Tencent, Huawei, and even Google Play) to populate themselves with apps. Developers often contact us because they have discovered their apps or games are popping up on Chinese app stores without their knowledge or permission.
Most of these bot-run stores are unresponsive to takedown requests, if they even have working contact information at all. The longer a game has been available on Google Play, the more likely it will eventually show up on one of these stores, and getting the store to remove the game is challenging or impossible.
If you plan to publish an app or game in China on Chinese mobile app stores, here are our suggestions:
While regulations and requirements are constantly changing in the Mainland China app and game landscape, AppInChina stays abreast of the most current legal requirements to keep our clients and partners legally compliant at all times. We exist to make a complicated process simple, so you can focus on your software, while leaving the rest to us.