Service
ICP filing & compliance for foreign companies
TL;DR
- Most mainland-hosted commercial sites need ICP filing (Bei'an); online platforms may need an ICP license.
- Typical filing timeline: 2–4 weeks with complete documents and a qualified entity.
- Operating without filing risks domain blocking and enforcement.
- Sequence it: entity → filing → CDN → Mini Program → merchant — what runs in parallel.
- Who holds what: six instruments, one of them held by the CDN operator — the obligations matrix.
Regulatory requirements are often the gate before any technical launch in China. Chinagateway.pro helps global teams align entity structure, hosting choices, and filing workflows so your domain stays online and audit-ready.
ICP filing process (overview)
- Entity readiness — Confirm a mainland company or qualifying partner (e.g. WFOE) that can hold the filing.
- Hosting selection — Choose a mainland provider that accepts your entity type and business category.
- Document preparation — Business license, domain certificates, responsible person ID, and authorization letters.
- Submission & review — File through the provider portal; respond to regulator or provider queries.
- Display & maintenance — Publish the ICP number on-site; renew or update when domains or entities change.
Filing vs license
ICP filing (Bei'an / 备案) is the baseline registration for most websites hosted on mainland servers. ICP license (ICP证) applies to commercial online services such as marketplaces, paid platforms, or certain regulated categories. We help you determine which path matches your product before you commit architecture. For a side-by-side breakdown, see ICP filing vs ICP license: which one you need. Quick definition: ICP license (ICP证).
What we deliver
- Filing vs License Classification — Determine whether your product needs the baseline ICP filing (Bei'an) or the commercial ICP license before you commit architecture — the trigger is what your product does, not where it is hosted. ICP filing vs ICP license: which one you need
- Entity Readiness Assessment — Confirm a mainland-registered company or qualifying partner (typically a WFOE) that can hold the filing. A Hong Kong entity alone does not qualify. WFOE vs Hong Kong company, explained
- Document Preparation & Submission — Align technical prerequisites (hosting, domain, HTTPS) with filing rules. Assemble business license, domain certificates, responsible-person ID, and authorization letters; file through the provider portal and respond to regulator or provider queries. ICP filing timeline for foreign companies
- Post-Filing Maintenance & Updates — Publish the ICP number on-site and keep it displayed. Renew or update the filing when domains, entities, or services change. ICP filing for foreign companies — the step-by-step timeline
- Compliance Timeline Planning — Checklists and timeline planning for product and engineering teams, aligned with your launch date and review times that vary by province and business category. MIIT — the regulator behind ICP
Which engagement path matches your product?
Three paths, from lightest to most involved. The trigger is what your product does — not where it is hosted.
1. ICP filing only
For: Marketing sites, content sites, corporate pages — purely informational products.
Covers: Baseline ICP filing (Bei'an). Register domain + operator. Typically 2–4 weeks with complete documents and qualified entity.
Trigger: The product does not charge for access, hosts no third-party sellers, and is not a regulated category.
ICP filing vs ICP license: typical products2. Hong Kong entity + ICP filing
For: Companies operating through an HK entity that need mainland hosting.
Covers: The filing still requires a mainland-registered company or qualifying partner — an HK entity alone does not qualify. If the group operates through a WFOE, the WFOE holds the filing. The HK entity can sit above the WFOE in the corporate structure, but the filing sits on the mainland entity.
Trigger: Same as Card 1 — informational product. Entity layer adds a setup step, not a different permit.
Can a Hong Kong entity hold the ICP filing?3. WFOE + commercial ICP license
For: Marketplaces with third-party sellers, platforms that charge for access, SaaS/paid platforms, regulated categories.
Covers: ICP filing (baseline) + ICP license (ICP证) — a separate, longer permit process layered on top. The license triggers when the product model crosses into third-party-seller marketplaces, platforms that charge for access, or regulated categories.
Trigger: The product model crosses into commercial online platforms or paid services — filing alone does not cover that activity.
What products trigger the ICP license?Ongoing care: The ICP number must stay displayed for the life of the site. The filing needs maintenance — renew or update it when domains or entities change — and the license question stays open: if the product later crosses into paid services or regulated categories, the ICP license applies on top of the filing. ICP filing vs ICP license
How we work
| Phase | What happens |
|---|---|
| 1. Discovery & audit | Map your entity structure, hosting choices, and compliance gaps. Run the 10-point self-check first. |
| 2. Architecture & compliance | Define the entity/ICP route, hosting selection, and document checklist with clear timelines. See the full launch sequence and the obligations matrix. |
| 3. Build & integrate | Prepare documents, file through provider portals, and coordinate with legal counsel on WFOE or local partner structures. |
| 4. Launch & optimize | Publish the ICP number on-site, hand over maintenance runbooks, and plan updates when domains or entities change. |
China launch sequencing: what gates, what runs in parallel
A China launch is a sequencing problem, not a paperwork problem. One filed mainland entity underpins the domain filing, the Mini Program, and the merchant account — so the entity gates everything. After it, three workstreams overlap: the website filing runs its 2–4 week window while CDN configuration is planned inside that same window, and the Mini Program filing and merchant onboarding run their own, separate pipelines. Only the enablement steps are strictly serial.
| Step | Track | What happens | Documented window | Gates |
|---|---|---|---|---|
| 1. Mainland entity (WFOE) | Serial gate — blocks every row below | WFOE registered with a valid business license before any filing work begins. A Hong Kong entity alone does not qualify. Entity rules explained | No documented duration — a long-lead prerequisite that cannot be rushed | Underpins the program, the domain filing, and the merchant account |
| 2. ICP filing (website) | Serial gate — mainland domain serving waits for approval | Hosting selection (provider must accept your entity type and category), the four fixed documents, submission and review through the provider portal. Phase-by-phase timeline | Typically 2–4 weeks, varying by province and business category — starts only once entity and documents are complete | Mainland site goes live; CDN acceleration can enable; mainland-hosted checkout can launch |
| 3. CDN configuration | PARALLEL TRACK — plan and configure inside the Step 2 window; enable after approval | China-site account (international accounts cannot file), file the apex domain, add subdomain acceleration domains, HTTPS certificates, CNAME switch, test from inside China. CDN prerequisite chain | Configuration planned inside the 2–4 week filing window; subdomains ride the apex filing — no separate filings | Unfiled domains resolving to mainland servers are blocked until the filing completes |
| 4. Mini Program filing | PARALLEL TRACK — own pipeline under the same entity, not the website estimate | Five stages: form → platform initial review → MIIT SMS verification → provincial review → filing number auto-displays on the published program. The five-stage flow | Platform review 1–2 working days; SMS verification within 24 hours; provincial review 1–20 working days | WeChat publishes no unfiled program — publishing fails with error 86369 until the filing completes |
| 5. Merchant onboarding | PARALLEL TRACK — runs on the same filed entity; the binding waits for Step 4 | Apply on the path that matches your entity; after approval sign online and bind the merchant ID to the verified Mini Program's APPID. Choose the settlement currency before submitting — it is locked at registration. Acceptance paths & requirements | Mainland path 1–2 working days; overseas-direct 7–15 days by email; institution-partner set by the institution | Checkout goes live only when the merchant ID is bound and, for mainland-hosted checkout, the filing is approved |
Reading the tracks: strictly serial are the enablement gates — entity license first; filing approval before the mainland domain, CDN acceleration, or mainland-hosted checkout serves traffic; Mini Program filing before WeChat publishes; merchant binding after the program is verified. Everything else overlaps: plan CDN work inside the filing window, start the Mini Program filing and merchant onboarding as soon as the entity exists, and keep a hybrid global path live while entity and filing work progress in parallel.
Durations on this map come from the linked pages — the only fixed website window documented is the 2–4 week submission-and-review period; the Mini Program flow carries its own stage windows and must not inherit the website estimate. Practical guidance, not legal advice.
The dated instruments behind these gates — the MIIT filing notices, the CAC data orders, and the platform deadlines — are lined up with their effective dates in the regulations timeline.
Who holds what: the obligations matrix
A mainland China launch involves six distinct instruments — filings, licenses, and platform bindings — held by different parties. Five of them are brand-side obligations: the ICP filing, the APP filing, the PSB follow-on, the ICP license (when the product triggers it), and the WeChat Pay merchant account. One is not: the CDN license is held by the CDN operator — the brand never holds or obtains it. Teams routinely blur that line or assume one entity holds everything. The table below maps each instrument to the party that holds it, what the brand controls, and where the identifier surfaces in practice.
| Instrument | What it is | Who holds / obtains it | Brand controls vs operator handles | Where it shows up |
|---|---|---|---|---|
| ICP filing (Bei'an, 备案) | Mandatory registration for most websites hosted on mainland servers. Registers the domain and its operator with the authorities. | The brand's mainland entity — typically a WFOE. A Hong Kong entity alone cannot hold the filing. Filed through the hosting provider's portal; the provider forwards it through the MIIT review chain. | Brand controls: entity choice, domain, hosting provider; filing updates on domain/entity changes. Provider handles: portal submission, initial review (1–2 working days, with phone verification), then forwarding into MIIT SMS verification (within 24 h) and provincial Communications Administration review (within 20 working days). | ICP number displayed in the page footer for the life of the site. Timeline: typically 2–4 weeks with complete documents and a qualified entity. |
| ICP commercial license (ICP证) | Separate permit for commercial online platforms and paid services — marketplaces hosting third-party sellers, platforms charging for access, and certain regulated categories. | The brand's mainland entity (same baseline as the filing — a WFOE or qualifying partner). Category eligibility must be confirmed with counsel. A layer on top of the baseline filing, not a substitute. | Brand controls: the classification decision — filing-only vs filing-plus-license; category eligibility depends on the business scope — confirm with counsel. Provider handles: N/A — the license is a brand-side permit, not an operator permit. | Separate, longer permit process beyond the 2–4 week filing window. Own renewal duties set by the permit. Trigger follows what the product does, not where it is hosted. |
| CDN license (增值电信业务经营许可证—CDN) | MIIT-issued permit that authorizes an operator to run CDN services in mainland China. | The CDN operator — not the brand. JD Cloud holds the MIIT licenses behind Cloudflare's China Network. The mainland edge is a licensed-operator-only market — without a licensed operator there is no mainland edge; Alibaba Cloud CDN and Tencent EdgeOne are mainland CDN products. The license is the operator's permit to run the edge; the ICP filing is the site's permit to be hosted. Different instruments, different parties. | Brand controls: nothing directly — the brand selects a licensed operator but does not hold or obtain the CDN license. Operator handles: license compliance, edge-node operation, content vetting (e.g. JD Cloud vets content for the Cloudflare China Network). | The brand never holds it — what the brand sees is the effect: only MIIT-licensed operators can deliver content from mainland edge nodes. The operator license and the site-level ICP filing are different instruments held by different parties. |
| APP filing (APP备案) | ICP registration for native mobile apps whose backend domains resolve to mainland servers. Same MIIT pipeline as the website filing, but a separate service registration under the same filing subject. | The brand's mainland entity — the same filed entity that holds the website ICP filing. Same hosting-provider portal pipeline. | Brand controls: the app as a registered object — app identity and backend domain — plus change and cancel filings on it. Provider handles: the provider-portal stage; the pipeline then runs MIIT SMS verification (12381) and provincial Communications Administration review — the same stages as the website filing. | APP filing number hangs off the subject number as a separate serial with an -A suffix (pattern: 鲁ICP备09090609号-2A). Distribution bar: access providers, distribution platforms, and terminal makers must not provide access, distribution, or pre-installation for unfiled apps. Governed by MIIT notice 工信部信管〔2023〕105号. |
| PSB follow-on filing (公安备案) | Public-security (police) registration that happens after the ICP filing number issues. MIIT runs the ICP pipeline; public security handles its own registration afterward. Also the instead-of-ICP gate for CDN acceleration domains serving only outside the mainland (Hong Kong, Macau, Taiwan). | Brand-side launch-checklist step — planned once the ICP filing number is in hand. Sequential from the ICP filing. Portal: beian.mps.gov.cn (Chinese-only). |
Brand controls: timing — it is planned into the launch timeline once the ICP filing number is in hand. Provider handles: nothing — public security runs its own registration after the MIIT pipeline (provider review → provincial Communications Administration review → number issuance) ends. | Follows ICP number issuance. Separate authority (public security, not MIIT) — sequential, not interchangeable. For outside-mainland-only acceleration (Hong Kong, Macau, Taiwan): the PSB filing replaces the ICP filing as the access gate. |
| WeChat Pay merchant account (merchant ID ↔ APPID) | The acceptance-side account behind every WeChat Pay checkout. On the mainland path, an agreement signed with WeChat Pay, with a merchant ID bound to your Mini Program's APPID. Onboarding runs on pay.weixin.qq.com. |
The brand's mainland entity — the same filed entity (typically a WFOE) that holds the ICP filing typically holds the merchant account. Three paths: mainland (mainland-registered entities), overseas-direct (Hong Kong merchants per the official FAQ), institution-partner (no direct agreement — the institution signs with WeChat Pay). | Brand controls: path selection; settlement currency (fixed at registration, cannot be changed later); surface choice — Mini Program vs H5 is a separate decision. WeChat Pay handles: merchant ID issuance and binding to the APPID; review (mainland: 1–2 working days). | Merchant ID bound to the APPID; onboarding runs on pay.weixin.qq.com. Settlement: 26 currencies, T+1, 800 USD minimum — 2020-era published lists, not confirmed current; currency locked at registration. The same filed entity underpins the Mini Program, the domain filing, and the merchant account. |
Reading the matrix: five of the six instruments are brand-side — held through the same mainland entity: the ICP filing, the APP filing, the PSB follow-on, the ICP license (when triggered), and the WeChat Pay merchant account. The sixth, the CDN license, is the exception — held by the CDN operator, never by the brand. And holding is not merging: the website filing, the APP filing, the Mini Program filing, and the merchant account are separate registrations that hang off one filed entity, each with its own pipeline and identifier.
The matrix covers the six instruments this site documents. A marketplace can additionally trigger the VATS / EDI (B21) transaction-processing permit — see the VATS / EDI license definition. Number formats for the license, PSB, CDN, and merchant identifiers are not stated in our sources and are deliberately left blank rather than filled in. Practical guidance, not legal advice.
Transferring providers, changing filing details, or stuck in review?
We decode the rejection comment and drive the resubmission — document fixes, provider coordination, and CA follow-up until the filing clears. Start with the documented catalog: ICP Filing Rejected: Common Reasons and the Fix for Each. Planning a provider switch or a clean exit? Follow the transfer-or-cancel sequence.
19+ years in R&D leadership and systems architecture behind every engagement — who we are · source citations
Pair this with mainland hosting and WeChat integrations for an end-to-end launch.
Frequently asked questions
Do we need a Chinese entity to file for ICP?
Yes. The filing holder must be a mainland-registered company or qualifying partner — for foreign brands, typically a WFOE (Wholly Foreign-Owned Enterprise). A Hong Kong entity alone does not qualify. If your group operates in mainland China through a WFOE, the WFOE holds the filing.
How long does the ICP filing take?
Typically 2–4 weeks for submission and review with complete documents and a qualified entity, varying by province and business category. The window starts only once a qualified entity and complete documents exist — entity setup, hosting selection, and document preparation add time before submission.
Does our product need the ICP filing or the ICP license?
The ICP filing (Bei'an) is the baseline registration for most websites hosted on mainland servers. The ICP license (ICP证) applies to commercial online services such as marketplaces, paid platforms, or certain regulated categories — the trigger is what your product does, not where it is hosted. A brochure site usually needs the filing only; your own catalog with checkout depends on the business model and should be classified early.
What happens if we launch a mainland-hosted site without a filing?
Operating a mainland-hosted site without a filing risks domain blocking and enforcement action — domain blocking means visitors cannot reach your site. Plan the filing before your launch date, not after.
What happens after the filing is approved?
You publish the ICP number on-site, and it must stay displayed for the life of the site. The filing also needs maintenance — renew or update it when domains or entities change — and the license question stays open: if the product later crosses into paid services or regulated categories, the ICP license applies on top of the filing.
Planning an ICP filing?
Email your product description, entity structure, and target launch window — we will classify filing versus license and map the sequence.
Email hello@chinagateway.proPrefer to scope it yourself? 10-point readiness check · deep dives: ICP filing timeline for foreign companies, WFOE vs Hong Kong company, explained, Reach China without an ICP filing — paths & trade-offs, Game Approval in China: NPPA Rules for Foreign Publishers, APP Filing in China: when a native app needs one, PIPL compliance requirements for foreign companies