Deadline for Smart Phone Applications and Mini Programs Filing
On 21 July 2023, to implement the Law of the People’s Republic of China on Combating Telecom and Online Fraud, Administrative Measures for Internet Information Services (2011 Revision), and other laws and regulations, to promote the standardized and healthy development of the Internet industry, and to further improve the management of mobile Internet information services, the Ministry of Industry and Information Technology of the PRC (“MIIT”) released a Notice on Carrying out the Filing of Mobile Internet Applications (Notice).
Among the working arrangements mentioned in the third article of the Notice, there are some points in time approaching this year that are worth noting.
- by the end of August 2023: Work preparation stage
- by the end of March 2024: Stock APP filing stage
- by the end of June 2024: Monitoring and inspection stage
- Starting from July 2024: Normalized work stage
The closest timing is the 2) Stock APP filing, which means enforcing the filing of mobile applications (Smart Phone Applications) and Mini Programs (such as WeChat and Alipay Mini Programs) (together hereinafter referred to as APPs). The deadline for filing completion is 31 March 2024.
All APPs for programs that engage in internet information services within the Mainland Chinese territory must comply with the filing obligations. Filings should be completed with the Provincial Communications Administration:
- For APPs pre-installed on a smartphone or downloaded by a user, filing should be completed through the relevant network access service provider. For example, the holder of an APP hosted on Tencent Cloud’s cloud service should conduct filing through the Tencent Cloud portal.
- APPs based on an API that users can use without installation, such as Mini Programs, Quick APPs, etc. must be filed through their distribution platform. For example, Mini Programs in WeChat should conduct filing through WeChat.
APPs hosted outside of Mainland China cannot be filed, which means these APPs will need to convert to local servers and domain names to continue running in Mainland China.
Network access service providers, APP distribution platforms, and smartphone manufacturers cannot provide network access to, distribute, and preset APPs that have not completed filing obligations. This means that APPs will be removed from APP stores and mini-program platforms if the holder fails to file before the deadline.
Several provincial Communications Administrations have recently issued official notices that they plan to take enforcement actions against APP holders who fail to file, including but not limited to removal from App stores, blocking APPs, and restricting APP upgrades.
It is strongly recommended that companies take action to complete the filing process by the end of March. You can also find the “Internet Information Service Filing Registration Form. wps” attached to the Notice.
Please feel free to contact us for more information.
References:
Law of the People’s Republic of China on Combating Telecom and Online Fraud
Administrative Measures for Internet Information Services (2011 Revision)
