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 service commercial information service?
Character.
Character02
Or is it VATS catalogue (IDC/CDN/EDI/…)?
Catalogue.
VATS03
Filing already done?
Necessary not sufficient.
Filing04
Foreign investment allowed for that item?
FIE overlay.
FIEWorking rule: map the monetised function, host/operator, customer and ownership structure against the current telecom catalogue.
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 certificate as ‘we are licensed’
Sales fiction.
Fail.
One licence for every SaaS feature
Catalogue blindness.
Map.
use telecom related guide
detailed treatment treatise.
Link FLAG.
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.
01Product feature listWhat users do.
02Revenue modelCommercial signals.
03Entity ownershipFIE limits.
Questions people ask before they build.
Short answers for orientation. The right result can change with the service model and current rules.
Do all shops need an ICP licence?
Many need filing; commercial licensing depends on activities. Catalogue mapping beats slogans.
Where is the related guide map?
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.