ICP filing vs ICP license: which one applies to your website?

Many guides and agencies say ICP license for both of these. They’re different in cost, conditions and who can get them.

This guide helps you work out which one you’d need. It’s part of the legal basics of a website in China, and it follows on from the wider ICP license question.

Start with one check: is your site served from mainland China? Alibaba Cloud says filing applies only to mainland servers,⁵ and Cloudflare extends the requirement to sites delivered through a CDN in China.² If neither is true, China Briefing says you don’t technically need either, though the site may be blocked at times.³

What is the difference between an ICP filing and an ICP license?

A filing registers a site. A license permits paid activity. China’s rules set a filing system for non-commercial internet information services and a licensing system for commercial ones.¹

	ICP filing	Commercial ICP license
Chinese term	备案 (Bei’an)	经营许可证 (ICP Zheng)
Nature	Registration	Permit
Covers	Free, public information 1	Paid services 1
Government fee	Free, your provider may charge 2	Not published in our sources
Sample number format 14	京ICP备2021123456号	京ICP证123456号
Legal review clock	20 working days once complete 7	60 days 1
Estimated time	About 3 to 8 weeks 34	2 to 6 months 3
Upkeep	Change filings, plus an annual review in the text, practice unconfirmed 6	5 years, then renewal 3

The estimates vary because they measure different things. AppInChina’s 6 to 8 weeks includes preparation.⁴ Cloudflare says 1 to 2 months for a filing and 2 to 3 for a license.² AWS China says review alone can take 1 week in Shanghai and 3 in Gansu.¹⁵ Our ICP cost and timeline guide sets them side by side.

The filing also comes first. A company must already hold a filing before it applies for a license.² So a commercial site has both, not one or the other.

Which one does your website need?

Ask whether visitors pay for anything on the site. The rules define a commercial service as providing information or web page production to users for a fee, over the internet.¹

China Briefing reads that widely, and lists advertising, subscriptions, paid downloads, in-app purchases and online sales as triggers for the license.³ The rule text never uses the word “commerce,” so the gray areas below come from that gap.

Your site	Likely need
Presents your company, ends with a contact form	Filing 11
Blog or guides, free to read	Filing 11
B2B site used as a sales channel, no online payment	Filing, but MSA Asia warns MIIT may class it as commercial 11
Paid subscriptions or paid downloads	License 3
Advertising income on the site	License 311
Online checkout for your own products	Sources disagree, see below
Marketplace between third-party buyers and sellers	A different license (EDI, B21) 3

Stay inside the box you chose. The rules bar providers from going beyond their licensed or filed scope, and they bar non-commercial providers from paid services.¹ A filed site that starts charging online is outside its filing.

Some topics need a sector approval first. In fields such as news, publishing and education, where the law requires it, you need that approval before you apply for a license or complete a filing.¹ So this isn’t only a license question.

Who can apply?

In practice, a Chinese legal entity. Overseas companies generally can’t file with only their foreign registration.⁴ Both the filing and the license require a Chinese business entity, according to China Briefing, which also names working through a licensed local partner.³ We found no source that explains how that works.

• Filing: Cloudflare lists representative offices, WFOEs, joint ventures, local companies and individuals with personal sites.² Alibaba Cloud won’t accept organizational content under a personal filing.⁸
• License: Conditions are stricter, and the sources differ for foreign-owned companies. Our ICP license guide sets out where they disagree, and our guide to working without a Chinese company covers the alternatives.

You file in the province of your domicile,⁶ which AppInChina describes as where your business license was issued.⁴ AWS China adds that your actual office should be in that same province.¹⁵

How the ICP filing process works

You rarely deal with the government directly. You apply through the management platform of your hosting provider, and it passes your file to the provincial authority.⁴

1. Have a Chinese entity. Your own, or a partner’s if a local adviser confirms that route for your case.
2. Prepare your domain. See the checks below, since a domain problem stops the file.
3. Choose an approved mainland host. Alibaba Cloud says its international accounts can’t submit filings, so you need a China site account there, and its filing system is in Chinese only.⁵
4. Submit through the host. It checks that the file is complete.⁴
5. Answer the MIIT text message. On Alibaba Cloud, the named people must validate within 24 hours, or the process restarts.¹⁰
6. Wait for provincial review. The bureau has 20 working days once the file is complete. If it’s incomplete, you’re refused and told why within the same window.⁷
7. Publish your number. It goes at the bottom of your homepage, and the filing appears in MIIT’s system.⁶⁷

Don’t launch first. The filing Measures bar non-commercial services before filing, and they bar access providers from connecting unfiled sites.⁶

Domain checks

Alibaba Cloud lists these conditions. Other hosts may differ, so ask yours.

Check	Alibaba Cloud’s rule
Suffix	Must be MIIT-approved. It gives .org as a suffix it can’t file 9
Registrar	Must be MIIT-approved, or the domain must be transferred 9
Real-name verification	Required, and it must match the filing entity or its representative 9
Waiting time	2 to 3 days after a change, for MIIT to sync 9
Remaining validity	More than 45 days, varying by province 9

If your domain is held in your foreign company’s name, this is where it surfaces. See whether you need a .cn domain before you buy anything new.

Documents

AppInChina lists these documents:⁴

• Business license and legal entity details
• ID and contact details for the legal representative
• Proof of domain ownership
• Hosting agreement with an approved Chinese provider
• Website details: content, purpose and audience

Requirements can vary by province, and some items may need Chinese versions, so check with your provider first.

Free check

Is your website visible on Baidu?

Enter your website. We check Baidu, access from China and how your site is set up, then email you the report.

Your websiteCheck my site

What a commercial license adds

A license is a much bigger commitment than a filing. China Briefing lists these conditions for category B25:³

• A Chinese entity
• RMB 1 million in registered capital for one province, or RMB 10 million across provinces
• At least 3 dedicated staff with social security records
• Servers in a licensed mainland data center
• A named cybersecurity officer and an incident plan

China Briefing adds that sectors such as health, finance, education, news and gaming need their own approval before MIIT will process the application.³ The authority has 60 days to complete its review once it receives the application.¹

RMB 1 million

Capital for one province

3

Dedicated people

5 years

Validity

China Briefing, April 2026

What comes after the filing

The filing isn’t the last step. Here’s what follows.

• Show your number. It goes at the bottom center of your homepage, with a link to MIIT’s filing system below it.⁶ This is a national rule, not a provincial option.⁷ Our legal overview shows how to read and check a number.
• File with public security. This PSB filing is a separate step, due within 30 days.³⁴
• Report changes in advance. Changes to filed details must be submitted 30 days beforehand.⁶
• Ask about the annual review. The Measures still provide for one each year, online,⁶ but we couldn’t confirm how it runs today. Ask your host what your province requires.

Sources differ slightly on when the PSB clock starts: AppInChina says from approval or from the site going live.⁴ Our guide on what a PSB filing is has the detail.

What happens if you skip it?

Your host is the first risk. Access providers may not serve unfiled sites,⁶ and Cloudflare says China-based hosts are told to shut them down, often without notice.²

The written penalties depend on the failure:

Failure	Consequence
No filing, or beyond the filed scope	Correction order, then closure if you refuse 1. The filing Measures add RMB 10,000 for no filing, and RMB 5,000 to 10,000 for scope 6
False filing information	Site closure and cancellation of the filing 6
Number not displayed	Correction order and a fine of RMB 5,000 to 50,000 1
No link under the number	Correction order, then RMB 5,000 to 10,000 if you miss the deadline 7

The two texts don’t line up neatly, since the State Council Measures name no fine for a missing filing. AppInChina’s CNY 10,000 to 50,000 matches neither,⁴ so ask a local adviser. For paid services with no license, see our ICP license guide.

The bottom line

If your mainland site only informs, you need a filing. If it charges online, plan for a license too, and that’s a far larger project. Sites served from outside the mainland generally need neither.

You don’t have to settle this on day one. You can start with hosting in Hong Kong and compare your hosting options in China later.

How Index in China can help

We translate your site into Simplified Chinese with a human reviewer, work on getting it indexed by Chinese search engines and send a monthly report on Chinese traffic.

ICP filings aren’t part of the offer we list, and we’ll tell you if your case needs a local adviser. We don’t promise rankings or traffic. See what we do.

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