The service function determines the candidate telecom item.
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FunctionCatalogue classification EntityLicence holder and access ScopeTerritory and approved activity
VATS · 02 Editorial guide
Value-Added Telecommunications Licences in China
VATS is an umbrella, not one licence. Break the product into catalogue functions such as internet information, IDC, CDN, online data processing and transaction processing, then match each function to the operating entity, infrastructure and customer contract.
First job Map each supplied function to the current telecom business catalogue before testing ownership or licence scope.
Decision railfeature inventory → functional service flow → catalogue item → operator entity → facilities and third parties → geographic coverage → licence authority and application → ownership and FDI route → launch controls → changes, reporting and exit
See routing factsStart here
Key considerations
The first questions are about urgency, governance and preservation — before collection expands or interviews begin.
- What functions are supplied to customers?
- Which entity operates each function and controls infrastructure?
- What licence scope, territory and ownership limits may apply?
Direct answer
What this page decides
Owner
02
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A China VATS analysis begins with what the provider actually supplies, not its product name or software architecture. Break the service into functions and map each one to the current Telecommunications Business Classification Catalogue—for example IDC, CDN, internet access, online data and transaction processing, domestic multiparty communications, call centres, information services, information search, community platforms or information protection and processing. Then identify which entity contracts, controls the relevant platform or infrastructure, sets service terms, bills customers and bears operational responsibility. The licence must cover the correct service item and geographic area; a provincial licence does not authorise a cross-provincial operation. Outsourcing servers or network capacity to a licensed carrier does not automatically remove the customer-facing provider from the perimeter. Foreign-invested structures require a separate access analysis, including catalogue limits and the specific conditions of any approved pilot.
At a glance
Which fact changes the next route
Use the fact that changes ownership or urgency to decide the next move.
| Question | Why it matters | Next route |
|---|---|---|
| What function is supplied to the customer? | IDC, CDN, EDI and information services turn on technical and commercial function rather than branding. | Diagram inputs, processing, transmission, storage, outputs and customer control. |
| Who is the operator? | The entity signing a reseller or technology contract may still operate the regulated service if it controls delivery, pricing and users. | Map contracting, billing, platform control, support and liability. |
| Where is the service offered? | The approving authority and licence type differ between one-province and cross-provincial operations. | List customer, node, facility and service coverage by province. |
| Whose infrastructure is used? | Upstream carrier capacity, cloud, racks, CDN nodes and access lines affect classification and contractual compliance. | Verify each provider's licence item, coverage and resale rights. |
| Is foreign investment involved? | Ownership limits vary by service and policy route; pilot liberalisation is location- and approval-specific. | Trace ultimate ownership and test national, FTZ and 2024 pilot routes separately. |
Scope
What this page owns — and what it does not
Covers functional classification and operating-licence analysis for value-added telecommunications services.
Does not determine spectrum, numbering, equipment approval, cybersecurity review, content permission, data export or a specific application outcome.
One product can contain multiple regulated and unregulated functions, each of which should be allocated to the responsible entity.
Catalogue interpretation and pilot availability should be confirmed against current MIIT and provincial implementation before launch or restructuring.
Practical workflow
Action, evidence, legal gate, output
| Action | Documents / evidence | Legal gate | Output |
|---|---|---|---|
| Inventory customer-facing functions | Product specifications, demos, user journeys, pricing, terms and support model | Separate storage, processing, transmission, access, messaging, transactions and information functions | Function inventory |
| Map technical and contractual delivery | Architecture, data flow, network topology, facilities, vendors, contracts and invoices | Identify who controls and supplies each regulated capability | Service responsibility map |
| Classify catalogue items | Function matrix and current catalogue definitions | Test each function against the complete definition and exclusions | Reasoned VATS classification |
| Define coverage and authority | Customer locations, nodes, facilities, service area and rollout plan | Choose provincial or cross-regional licence route and matching coverage | Licence and geography matrix |
| Test entity and ownership eligibility | Group chart, ultimate owners, business licence, capital, staff and operating resources | Apply domestic, foreign-invested or approved pilot conditions | Applicant eligibility analysis |
| Prepare application and operating controls | Business plan, technical plan, service quality, security, user protection and continuity measures | Align application claims with the production service and resources | Application-ready evidence set |
| Control changes and exit | Licence, annual reports, product changes, M&A, coverage changes and user transition plan | Obtain required changes or cessation approval before material implementation | Licence lifecycle register |
Documents
What to gather before the next call
These items help clarify the file; they are not a legal requirement list.
| Item | Why needed | Who holds it | Risk if missing |
|---|---|---|---|
| Feature-to-catalogue matrix | Connects each real function to a reasoned regulatory category | Product, engineering and legal | Marketing labels conceal a regulated service |
| Operator and vendor responsibility map | Shows who contracts, controls, bills and supports each function | Business, procurement and compliance | A reseller label is mistaken for a perimeter exemption |
| Network and facility topology | Identifies nodes, resources, upstream providers and geographic coverage | Network, cloud and security teams | Licence scope does not match production architecture |
| Applicant and ownership file | Supports entity, capital, personnel and foreign-access eligibility | Corporate and regulatory teams | Ineligible applicant or undisclosed control |
| Security and service-quality controls | Demonstrates operating capability and user protection | Security, operations and customer service | Paper application cannot operate compliantly |
| Licence lifecycle tracker | Monitors scope, coverage, reporting, changes and cessation | Licence owner and company secretarial team | Business drifts beyond approved conditions |
Common failure points
Where files usually break
Classifying a service from labels such as SaaS, platform, marketplace or cloud without mapping the supplied telecom functions.
Assuming that buying capacity from a licensed carrier permits unrestricted resale under the buyer's own customer service.
Applying for commercial ICP while ignoring EDI, IDC, CDN, ISP, call-centre or other embedded functions.
Using a single-province licence for customers, nodes or service coverage extending across provincial boundaries.
Matching an upstream vendor's licence item but not its approved geography or the actual contracted service.
Treating foreign-investment pilot liberalisation as nationwide or automatic rather than location- and approval-specific.
Changing control, business item, coverage or operating model without completing the required licence procedure.
FAQ
Narrow follow-ups owned by this page
Does a software company automatically fall outside telecom licensing?
No. The classification depends on the function supplied and the provider's operational role, not whether the product is delivered as software or called SaaS.
Can a licensed infrastructure vendor cover its customer's service?
The vendor's licence covers its own approved operation. The customer must separately assess whether its customer-facing activity constitutes operation, resale or another licensed service.
When is a cross-regional VATS licence needed?
Where the regulated business coverage spans two or more provinces, the Telecommunications Regulations direct the application to MIIT for a cross-regional licence rather than a single provincial authority.
Did the 2024 pilot remove all foreign-investment limits?
No. It removes equity-ratio limits for specified services in approved pilot areas, subject to the pilot scope and an MIIT trial approval; excluded content fields and other requirements remain.
Decision map
Keep the question bounded.
- Decompose the productList hosting, compute, storage, delivery, platform, marketplace, messaging, connectivity and content functions separately.
- Map catalogue itemsCompare each function with the current MIIT catalogue and document why neighbouring items do or do not apply.
- Test entity and accessMatch licence holder, foreign ownership, geographic scope, infrastructure and operational control.
- Align contracts and operationsCustomer terms, invoices, branding, technical control and regulatory records should tell the same story.
Regulatory gates
Approvals that can hold signing or closing.
This map does not decide whether a filing is required on your facts.
Ownership and operating control must fit current access rules.
The live service must remain within the issued licence scope and geography.
Quick answers
Need the short version? Start with one narrow question.
These explainers answer one question. They do not replace this topic route or a deep guide.
Quick AnswerVATS Licence in ChinaVATS is China’s value-added telecom licensing catalogue — IDC, CDN, EDI and more live here, not under website Bei’an. Reviewed 6 Sep 2026.Quick AnswerInternet Resource Collaboration Services in ChinaInternet resource collaboration (IRC) is a VATS category around coordinated internet resources — related to but distinct from IDC/CDN. Reviewed 6 Sep 2026.Quick AnswerOnline Data Processing and Transaction Processing Licence in ChinaOnline data processing & transaction processing (ODP/EDI-adjacent catalogue logic) often appears in platform/SaaS licence maps. Reviewed 6 Sep 2026.Quick AnswerEDI Licence in ChinaEDI (electronic data interchange) style VATS items cover certain B2B electronic data exchange services — map against ODP carefully. Reviewed 6 Sep 2026.
Curated resources
Open the asset that matches this job.
01
Guide
02China ICP, VATS & Telecom Licensing Guide
Service classification, ICP filing, VATS catalogue items, foreign-investment access and operating-route analysis.
Guide
03Telecommunications Business Classification Catalogue
Official MIIT catalogue used to classify basic and value-added telecommunications service functions.
Guide
04Foreign-invested telecommunications enterprise provisions
Official rules governing foreign-invested telecommunications operators, subject to current catalogue and pilot measures.
Supporting guide
05PRC Telecommunications Regulations
Official administrative regulation establishing telecom service classification, licensing, provincial and cross-regional approval routes, operating obligations and supervision.
Supporting guide
06Measures for Administration of Telecommunications Business Operating Licences
Official MIIT rules covering licence types, approving authorities, application evidence, use, changes, reporting, security duties and cessation.
Supporting guide
MIIT Notice on the VATS Foreign-Investment Opening Pilot
Official 2024 pilot notice removing foreign-equity-ratio limits for specified VATS items in approved areas, subject to pilot scope and MIIT trial approval.
Helpful to prepare
Facts that make the next conversation clearer.
These items are orientation aids, not a legal requirement list.
Product and technical architecture mapEntity, ownership and operating-responsibility chartCandidate catalogue items and classification rationaleExisting licences, scope, territory and renewal datesCustomer, partner and infrastructure agreements
Counsel hand-off
What to bring when you instruct
Bring the full feature inventory and demos, product and customer terms, pricing and revenue flows, architecture and data-flow diagrams, network and facility topology, customer and node geography, upstream carrier, cloud and reseller contracts, every counterparty licence and coverage record, proposed applicant and ultimate ownership chart, staffing and technical resources, security and service-quality controls, existing licences and annual reports, rollout plan and anticipated product, ownership or geographic changes.
Local context
Add location only when the filing or pilot route changes.
National service classification comes first; infrastructure location, filing practice and approved pilots follow.
Open city and province guidesCounsel hand-off
Need technology and telecom counsel?
This hub organises filing, catalogue and operating-route questions. It does not determine licence scope or foreign-investment access on your facts.
Find technology counselLegal review
Who reviewed this guide
Need qualified counsel?
Move carefully. Move with a record.
Use the portal to identify counsel for this practice and related China-side issues.