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New government and app store requirements present fresh hurdles for apps and games in China

By Todd KuhnsPublished on May 29, 2021
New government and app store requirements present fresh hurdles for apps and games in China

Foreign companies attempting to publish their apps or games on the Chinese market must comply with two new requirements.

1. ICP Filing requirements expanded to more app stores

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.

Link: How Can I Get an ICP License or ICP Filing for China?

ICP Beian example
Example of an ICP Filing application.

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:

  • Domain purchased in China
  • SSL certificate
  • Hosted website with contents related to the app you are publishing in China (i.e. the app’s home page, introduction page etc)
  • ICP Filing application
  • Registry of website with the National Internet Security Management Service Platform

This is in addition to all the other materials currently required to apply for publication on a Chinese app store.

2. Games under game license review must not already be available on any Chinese app stores

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.

Link: How To Get A Chinese Game License

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.

Link: How To Publish My App In China

So how can I publish my app or game in China under these new requirements?

If you plan to publish an app or game in China on Chinese mobile app stores, here are our suggestions:

  • Find a Chinese partner to help with publication. The regulatory environment in China is constantly changing, and not every requirement has been clearly spelled out in print. An experienced China-based publishing company can navigate those waters for you to save you time, money and energy.
  • Develop a China-only version of your game. Not only does this make sense for localization, but you will most likely need a separate APK anyway with the necessary integrations for the Chinese market. Remember that some SDKs simply don’t work in Mainland China, so your APK will require alternatives.
  • Make your game free to download and ad-supported. If you are currently making money from in-app purchases only, find a way to change your business model to ads. If your game has in-app purchases, disable them. While you will still need an ICP Filing, the app stores do not currently require a game license for free, ad-supported games, which eliminates your biggest hurdle.
  • If you plan to get a game license to have a paid or in-app purchase game, then apply for your game license ahead of time, while your game is in development. Do not release your game publicly in any markets until you have that license in hand. Keep in mind that it can take a year or more to receive a game license, and your game cannot change substantively from what was provided in the license application.
  • If your game is already released online and requires a game license to release in China, then modify your game to create a substantively different version. Choose a good Chinese name; localize the language to Mandarin; modify the artwork, skins, and icons; make tweaks to the UI and menus; and consider changing some of the game play, taking away some features or adding new ones.
  • Consider this an opportunity to make tweaks to your game you’ve been thinking about for a while. The more different the game is from what is already out there, the more likely the Chinese regulatory authorities (NPPA) will treat it as a new game.

How AppInChina Can Help

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.

Whether you need distribution, compliance, localization, monetization or hosting, you can contact us to take care of your needs in China, giving you access to the world’s largest market.

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