Guidance

Regulatory FAQ

Critical insights on compliance architecture and market access.

01

Mandatory Partnership: Do I need a Chinese partner?

Yes. Under the 'Negative List' for foreign investment, foreign entities cannot directly hold an ISBN (Game License). You must partner with a 100% domestic Chinese entity to act as the legal operator and publishing applicant.

02

Timeline: How long does ISBN application take?

For imported games, typically 8-15 months. The process involves Provincial Press & Publication Bureau review, NPPA expert review, and final approval. Timelines vary based on content complexity and geopolitical factors.

03

Red Lines: What are the key content restrictions?

Prohibited content includes violations of the Constitution, endangering national security, promoting cults/superstitions, excessive violence, and obscenity. Content must also align with 'Socialist Core Values' and historical correctness.

04

AI Governance: When is Algorithm Filing required?

If your AI service has 'public opinion properties' or 'social mobilization capabilities' (e.g., LLMs, text-to-image, chatbots), you must complete a Security Assessment and file with the CAC (Cyberspace Administration) before public launch.

05

Cross-Border Data: Can I transfer user data overseas?

Strictly regulated. Small-scale transfer requires PIPL compliance (Standard Contract). 'Important Data' or large-scale personal info (>1M users) requires a CAC-led Security Assessment. Local hosting is strongly recommended.

06

Prerequisites: Is Software Copyright mandatory?

Yes. A Computer Software Copyright Certificate (issued by CPCC) is a mandatory prerequisite for both the ISBN application and listing on major Chinese app stores.

07

Minor Protection: How to handle Anti-Addiction?

Strict compliance is non-negotiable. All games must integrate the NPPA's real-name verification system. Minors (<18) are restricted to 1 hour of play (8-9 PM) on Fri/Sat/Sun and holidays only.

08

Monetization: Can I use Stripe/PayPal?

Generally, no. To legally monetize in China, you must integrate local payment rails (WeChat Pay, Alipay) through your domestic operating partner or a compliant cross-border payment aggregator.

Complex Scenario?

Consult Counsel