MLPS in China

MLPS is classify → (file) → test → remediate — not a sticker you buy.

Under CSL and the classified-protection regime, network operators grade systems (typically levels 1–5) by harm if the system is damaged. Class 3 and above generally means filing with public security, periodic testing by a qualified house, and a remediation loop. Class 2 is still a real grade with security baselines; it is not ‘do nothing’. Cloud tenants and landlords split responsibilities — both can have MLPS facts. Testing vendor lists and fee schedules are not published here.

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.

What is the system boundary?

App, network, cloud account, plant OT.

Boundary

What class is justified?

Harm to citizens, social order, national security.

Class

Is filing required?

Typical class 3+ filing with MPS.

File

Who tests and how often?

Qualified test house; cadence by class.

Test

Working rule: Under CSL and the classified-protection regime, network operators grade systems (typically levels 1–5) by harm if the system is damaged.

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

Buy a certificate

Did a vendor sell an 'MLPS certificate' without first documenting system grading?

MLPS is a graded compliance process, not a certificate purchase; verify the classification basis, filing status and testing or remediation evidence.

ISO equals MLPS

Is the team treating an ISO audit as a substitute for MLPS grading, filing or testing?

ISO certification and MLPS are different frameworks; map the system grade and required public-security and testing steps separately.

Class 1 to hide

Did IT pick class 1 for a payment platform?

Class follows impact, not preference.

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.

01System inventoryName, owner, users, data, connectivity.

02Prior reportsOld class and gaps.

03Cloud shared-responsibilityWhat the IaaS/PaaS already filed.

Common confusions

Questions people ask before they build.

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

Do foreign-invested companies need MLPS?

If they operate networks in China, yes they are in the operator set. Class still depends on the system.

Is class 3 mandatory for SaaS?

No. Many SaaS systems are class 2 or 3 depending on users and harm. Do not self-serve a class 3 promise on a page.

Primary authorities

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

PIPL (NPC / official text)

Cyberspace Administration of China

National laws database (NPC)

Gov.cn policy releases