In August 2023 the Ministry of Industry and Information Technology issued a notice on mobile application filing. It requires app operators providing internet information services in China to complete filing, and prohibits app internet information services without it.
The rule is not new; what changed is enforcement. Previously apps relied mainly on website ICP filing, with no direct correspondence between filing information and the app. The new mechanism requires the app itself to be filed and creates closed-loop verification through app stores, access providers and device makers.
Timeline
The notice provides a transition period of about ten months. From September 2023 to the end of March 2024, apps already in operation before the notice must file with the provincial communications administration where the operator is domiciled. From April to the end of June 2024, telecommunications authorities organise supervision and inspection, handling those still unfiled in accordance with law.
For new apps the rule is more direct: file first, then operate. Product schedules should include filing time rather than treat it as a post-launch formality.
Relationship with ICP filing
App filing is handled through the ICP/IP address/domain filing system. It shares entity information with website filing but adds app name, package name, platform and signature identifiers. Operators must ensure consistency between entity, domain and app information.
Common problems include: the entity is filed but the app is not; the app name differs from the filed name; multiple apps under one entity are not separately registered; access information is incomplete when using third-party distribution or cloud services. These surface during verification and can lead to removal from stores or restricted access.
Impact on businesses
First, app stores verify filing information, and unfiled apps may be unable to list or update. Second, network access providers verify filing and may restrict access. Third, device makers verify pre-installed apps. Together, the three links turn filing from formal compliance into a business precondition.
Companies building mini-programs, quick apps or SDKs should assess whether they are app operators and whether they provide services through a host app. Where the boundary is unclear, prepare to the stricter standard to avoid being blocked at distribution.
Practical steps
First, build an app inventory listing name, package name, distribution channels, access providers and owners. Second, verify entity filing information for consistency with the licence, domains and app. Third, prepare separate filing materials for each app rather than sharing one set. Fourth, put filing into launch milestones with time for correction. Fifth, follow local communications administration requirements, as formats vary.
Filing is not one-off. Renaming an app, changing the entity, adjusting domains or distribution channels may require updates. Managing filing information as part of routine change control is easier than remediating before an inspection.
For app filing and launch compliance, see our algorithm filing service and business licensing; for in-app personal information, see data compliance; for distribution cooperation, see commercial contracts.
This article is based on the Notice on Carrying Out Mobile Application Filing issued by the Ministry of Industry and Information Technology in August 2023. It is for reference only and does not constitute legal advice.