ICP Filing Is the Foundation; an ICP License Is the Right to Charge
Many people treat “ICP filing” and “ICP license” as the same thing. They’re two things—separated by RMB 1,000,000 of registered capital. Filing is the prerequisite for a site to be reachable in China; everyone needs it. An ICP license is the legal right to charge users; the bar is much higher. This lesson clears both up—and focuses on the one decision you must get right on incorporation day.
The State applies a licensing system to commercial internet information services and a filing system to non-commercial internet information services. Without a license or without completing filing procedures, no one may engage in internet information services.
Filing requires a domain plus a domestic server. Only after the process completes may your domain point at an onshore server and serve the public.
Entity docs, domain certificate, server info
Access provider (cloud vendor) first review, about 3–20 business days
Communications authority review, about 3–20 business days
Get the filing number; domestic users reach you normally
With filing: clear path
Filing number in the footer, DNS works, cloud vendor doesn’t block you. It’s the foundation of compliant operations—later ICP licensing, payments, and app-store listings all need it.
Without filing: blocked anytime
Point a domain at a domestic server without filing and the domain or server provider may force-block you anytime—users see 403/404. No matter how good the product, one block resets you to zero.
Watch the sequence: filing must finish before go-live. If you’re already blocked and then scramble to file, you eat those dozens of days of downtime yourself. Put it on the launch plan and run it in parallel with development.
Want to charge users and run commercial internet information services? You need an ICP license. Two gates hit at once when you apply.
Gate 1 · Registered capital
For value-added telecom within one province, registered capital must be at least RMB 1,000,000; cross-province is RMB 10,000,000. This is a statutory floor, not a suggestion—even RMB 990,000 fails formal review.
Gate 2 · Must explicitly include
Your business license scope must include “Type II value-added telecommunications services.” Missing that line and review stops cold—do a company registration change first, then re-queue.
(To engage in value-added telecommunications services, the following conditions shall be met:) … for operations within a province, autonomous region, or municipality, registered capital of no less than RMB 1,000,000; for nationwide or cross-province / autonomous-region / municipality operations, registered capital of no less than RMB 10,000,000.
So a small decision on incorporation day decides your commercialization speed a year later: write the full business scope at registration, including Type II value-added telecommunications services. Write it, and you file ICP materials later as-is; miss it, and you change the registry first, wait the process—time and money both wasted.
Three questions—then see the verdict.
- Individuals can do non-commercial filing, but many business forms (payments, store listings) effectively require a company entity—if you’re serious, file under the company.
- Filing info must match reality: change server, domain, or entity and update the filing so it doesn’t go stale.
- App-store listings also demand filing info; mini programs have matching filing rules—put both on the plan.
Short on registered capital and not ready for an ICP license? The road isn’t blocked.
- Pure content, pure tools, not charging users directly—non-commercial filing is enough.
- Need to charge but no license yet: a common bridge is distribution or resale through a licensed platform, keeping the commercial layer under a licensed entity. Match local Communications Administration practice.
- If you’re set on platform / SaaS charging, write registered capital at RMB 1,000,000 in one step—next lesson covers how that ties to the five-year paid-in requirement.
Filing is about credentials; actually connecting the domain to the server still needs DNS. Four traps in appearance order—check them on launch day.
- Fixed server IP → add an A record pointing straight at it; cloud-hosted (they give you a hostname) → add a CNAME pointing to it.
- Configure both apex (no www) and www, then 301 to one canonical host—don’t let two addresses compete; search engines treat them as two sites.
- Propagation has delay (TTL). After a change, wait ten minutes before debugging—don’t assume you misconfigured immediately.
- Right order: buy an onshore server, submit filing first, only after approval point DNS at the onshore server for public traffic.
- Reverse it and you get burned: DNS to an onshore server without filing, and the cloud vendor redirects visitors to a notice page—public downtime.
- You don’t have to stop building during filing: use a temporary domain or offshore node for debug, then cut DNS after approval.
- Filing binds “domain + provider + entity.” Switching cloud vendors requires a filing access change; skip it and the old provider may cancel access—domain blocked anytime.
- Same vendor, new IP usually needs no change; cross-vendor migration always does. Leave review time in the migration plan.
- Expired certs get a full-page red browser warning—as bad as downtime. Free certs (Let’s Encrypt, etc.) last only 90 days—auto-renew is mandatory; manual renewal you will eventually forget.
- At go-live, force HTTP→HTTPS and scan for mixed http:// resource references on the page.
What these four share: quiet until they explode on the worst day (release day, press coverage day). Make them four fixed items on the launch checklist and the domain–server link stays solid.
Filing and an ICP license are two things. Filing governs whether you can open the door; an ICP license governs whether you can take money.
Finish filing before go-live. Without it you can be blocked anytime; each of two review tiers takes 3–20 business days—schedule it.
ICP license gates: registered capital from RMB 1,000,000, business scope including Type II value-added telecom. Both required; either missing fails.
Write the full business scope on incorporation day. That free decision saves a future company-registry change plus another queue.
Sources: Measures for the Administration of Internet Information Services (State Council Decree No. 292, promulgated 2000), Article 4; Measures for the Administration of Telecommunications Business Operating Licenses (MIIT Order No. 42, effective September 1, 2017), Article 6. Filing review durations are the usual ranges published by major cloud vendors; provincial Communications Administrations vary. Verified for this lesson on 2026-08-10.