A Comprehensive Guide to China’s Game License (ISBN) Application Process (2026 Edition)

Introduction

For international developers, the Internet Service Book Number (ISBN, commonly referred to as a “Game License” or “Banhao”) is the definitive barrier to entry in the Chinese market. Without an ISBN, a game cannot be legally commercialized (via IAPs or advertisements) nor can it be officially operated on servers within Mainland China.

This article distills complex regulatory requirements into a practical guide, focusing on the core legal realities of applying for an Import Game License.

1. Core Legal Framework: The “Proxy Publishing” Model

Under China’s Negative List for Foreign Investment and the Administrative Provisions on Network Publication Services, foreign-invested enterprises (including JVs and WFOEs) are strictly prohibited from engaging in the network game publishing business.

Consequently, an international developer (the Copyright Owner) must appoint a purely domestic Chinese entity holding a Network Publication Service License to act as the “Publishing Unit” to submit the application.

The Legal Structure

• Copyright Owner: The international developer (owner of IP and source code).
• Publishing Unit: Responsible for final content review, official submission to regulators, and assuming political/legal liability for the content.
• Operator: Responsible for actual game operations, server maintenance, user data management, and revenue collection. This role is often assumed by the Publishing Unit or another domestic partner.

2. Key Prerequisites and Documentation

Before submitting an application to the National Press and Publication Administration (NPPA), several legal formalities must be satisfied:

(1) Proof of Copyright

You must provide official Copyright Registration documents from your home jurisdiction or a recognized international body.

(2) Notarization and Legalization of POA

The Power of Attorney (POA) authorizing the Chinese publisher to act on your behalf must undergo Notarization by a local notary public and Legalization (or Apostille, where applicable) by the Chinese Embassy or Consulate in your country.

(3) NCAC Contract Registration

For games involving foreign IP, the publishing agreement must be registered with the National Copyright Administration of China (NCAC), and a formal approval notice must be obtained.

(4) ICP Filing and Data Localization

The Operator must complete an ICP Filing for the game’s official website. Furthermore, the game servers and all user data generated in China must be stored locally within the PRC (in compliance with Data Localization laws).

3. The Approval Process and Timeline

Import games are subject to a higher level of scrutiny and longer wait times compared to domestic titles.

1. Provincial Preliminary Review (1–3 Months): The provincial branch of the Press and Publication Bureau (e.g., in Shanghai or Guangdong) conducts an initial audit of the materials.

2. NPPA Expert Review (6–12 Months): The application is moved to the central NPPA expert pool. This is the most arduous stage, typically involving 1–3 rounds of Notices of Modification.

   Common feedback: revealing clothing on female characters, excessive combat gore, improper use of English text, or failure of the minor protection system.

3. Official Granting of License: Once approved, the NPPA publishes the result on its official website and issues the ISBN 핵발단 (Approval Document).

Expected Duration: While official documents suggest a 80-working-day window, in practice, the process from initial application to final approval usually takes 10 to 15 months.

4. Regulatory “Red Lines”

Based on our recent case files, the following are high-frequency reasons for application rejection or delay:

• Loot Box Transparency: All randomized mechanics (Gacha/Loot boxes) must disclose precise percentage probabilities, and a “guarantee” (Pity) mechanism must be implemented.
• Territorial Integrity in Maps: Any world or regional maps shown in-game must strictly adhere to Chinese surveying standards (e.g., correct depiction of the South China Sea “Nine-Dash Line” and Taiwan).
• Minor Protection System (Anti-Addiction): The version submitted for review must be integrated with the NPPA’s Real-Name Verification System. It must hard-code restrictions on playtime for minors (currently limited to 8 PM – 9 PM on Fridays, Saturdays, Sundays, and public holidays).
• Gore and Corpse Models: Splattering liquids of any color (including green) may be flagged as gore. Skeletons and corpses usually require model modifications or “reskinning.”
• Political Sensitivity: Content involving national sovereignty, historical events, or political figures is strictly reviewed. Anything deemed controversial will lead to an immediate rejection.
• Core Values: Content must align with “Socialist Core Values,” avoiding the promotion of violence, gambling, or occult superstitions.

5. Cost Structure Analysis

Official Fees: 0 RMB. The NPPA does not charge any administrative fees for ISBN applications.

Commercial Costs:

1. Agency/Publisher Fee: Paid to the Chinese Publishing Unit for their audit and filing services. This usually ranges from ¥50,000 to ¥100,000 RMB.
2. Localization and Modification: This is the largest hidden cost. If a game is not designed with compliance in mind, the development team may spend months of manpower refactoring art assets and code to meet modification notices.
3. Legal and Notarization Fees: Approximately ¥30,000 to ¥80,000 RMB depending on the jurisdiction and complexity.

Conclusion

Applying for a Chinese Game License is not merely an administrative procedure; it is a complex Compliance Engineering project. It requires developers to perform a deep “compliance makeover” of their code, art, and text while attempting to preserve the core fun of the game.

If you are planning to bring your game to China, we strongly recommend involving legal counsel at the Pre-development phase for a compliance audit to avoid invasive and costly modifications later.

Contact Us to schedule your initial compliance assessment.

Disclaimer: The content of this article is based on regulatory policies at the time of writing and does not constitute formal legal advice. China’s gaming regulations are dynamic; please consult with a professional attorney for specific matters.