The classification screen

4 questions before you choose the route.

This page identifies the right question and evidence. It does not determine the legal outcome on a reader’s facts.

01

Is the website or app hosted in mainland China?

Hosting location is a threshold fact for the ordinary ICP filing route.

Hosting
02

Who is the filing sponsor and service operator?

Identify the registered entity, domain holder, host and actual operator before filing.

Operator
03

Is the service non-commercial internet information or a regulated telecom function?

A filing does not replace licensing when the product performs a regulated VATS activity.

Classification
04

Do you only need a filing process, or a telecom classification?

Use the filing guide for sponsor, host and filing steps; use the telecom guide when the product itself may be licensed.

Decision factor

Working rule: Confirm where the service is hosted, who is the filing subject and whether any revenue-generating telecom function goes beyond ordinary filing.

What changes the answer

The signal ledger.

These facts move the question beyond a label and into a product, money-flow and control analysis.

Signal
Ask the operating question
Why it changes the route
Bei’an treated as a commercial licence
Is the business assuming ICP filing authorises any monetised online service?
Filing is not a substitute for a commercial ICP or another VATS licence.
Broader telecom classification needed
Does the product perform hosting, CDN, data-exchange or transaction-processing functions beyond ordinary internet-information filing?
If yes, classify the actual telecom service before launch.
Foreign-invested operator
Is a foreign-invested entity the website/app operator?
Test the ownership and market-access rules for the actual online service rather than assuming a WFOE can operate every platform model.
Prepare before you escalate

Bring a compact evidence docket—not a pitch deck.

Give a compliance team or counsel the operating facts that reveal the perimeter.

01Hosting contractWhere it lives.
02Domain and entity licencesFiler.
03Product monetisation mapFiling vs VATS.
Common confusions

Questions people ask before they build.

Short answers for orientation. The right result can change with the service model and current rules.

Is ICP filing the same as ICP licence?

No. Bei'an filing and commercial or licensed activities are different processes. Icp licence in china and /vats-licence-in-china.

When should I use the detailed ICP filing guide?

Use it when the immediate task is the filing process itself: sponsor/entity preparation, host submission, domain details, required documents and filing sequence.

Primary authorities

Reviewed sources support orientation, not a fact-specific assessment.

Ministry of Industry and Information Technology (MIIT)
Cyberspace Administration of China (CAC)
National laws database (NPC)
Telecom business catalogue / MIIT licensing