If the product is connectivity, hosting, CDN, online data processing or similar catalogue items, you are in VATS — not ‘just ICP filing’.
Value-added telecommunications services (VATS) are licensed against MIIT’s telecom business catalogue. Foreign investment is restricted or prohibited for many items; structures and partners matter. Website Bei’an does not substitute for a VATS licence. This wiki is the umbrella definition. Atomic pages cover IDC, CDN, EDI, online data processing/transaction processing, and internet resource collaboration. The live ICP/VATS telecom guide stays the deep flagship — we do not rewrite it here.
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.
Which catalogue item matches the product?
Map.
ItemIs FIE capital allowed for that item?
Ownership.
FIEIs Bei’an being mistaken for VATS?
Split.
Not filingNeed atomic licence page?
IDC/CDN/EDI…
AtomicWorking rule: Map the regulated role before marketing or launch in China.
The signal ledger.
These facts move the question beyond a label and into a product, money-flow and control analysis.
Bring a compact evidence docket—not a pitch deck.
Give a compliance team or counsel the operating facts that reveal the perimeter.
Questions people ask before they build.
Short answers for orientation. The right result can change with the service model and current rules.
Is SaaS always VATS?
Not always — and sometimes more than one item. Open /saas-in-china and map features.
Where is the deep flagship?
Keep /china-icp-vats-telecom-law.
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.