As an independent mobile app development agency in China, working with many multi-national companies, we’ve recently been asked a lot of questions regarding the new policy on Apple’s App Store, regarding ICP licenses and how it affects apps. In this article, we will answer some questions about where this has the biggest impact, who it impacts the most, how it impacts existing apps currently distributed, and how it impacts plans for new apps to be launched in China.

The most significant impact of this new policy will be on the Apple App Store, where all apps distributed in China will require an ICP license.

Can I still publish apps in China on the Apple App Store without an ICP license?

No. Since September 1st, 2023, no new apps can be submitted without an ICP license and apps already published and distributed in China require an ICP license to submit further updates to the App Store.

Will my existing app be removed from the Apple App Store in China?

Yes. As of March 2024, all existing apps published on the App Store in China will be removed if they have not updated their information to include their ICP license on the App Store.

Who will China's app ICP policy affect the most?

International apps will be affected the most. Those who are unable to meet the requirements to obtain an ICP license will have their apps removed from the Apple App Store in China after March 2024.

Who is eligible for an app ICP license?

The app ICP process is similar to typical website ICP in that both enterprise developers and individual developers are allowed to apply for ICP, as long as the person in charge of the app has a Chinese ID card, and the business scope of the app is legal.

What are the requirements for applying for an app ICP license?

  1. To obtain the app ICP, you will need to obtain the ICP for the app's website first, and the owner of these two ICP certificates should be the same person in China.

  2. The domain name to apply for the ICP should be hosted on a domestic domain registrar and be verified by real name, and it has to be the same person as the ICP owner. It should be noted that domain suffix like '.app', and '.chat' for example, are not acceptable to be registered in China, the recommended suffix are '.com' and '.cn' etc.

  3. The server that the app connects to has to be located in China.

  4. Additional information about the app needs to be submitted for the app ICP application. This includes the app name, app icon, app language, public key registered on the app store, and the MD5 value of the app certificate.

What other options are available if I’m not eligible for an app ICP license?

While some companies offer proxy ICP services, this is a very grey area and is likely to be cracked down on very quickly. If your domain gets blacklisted and blocked in China it is very hard to get it unblocked. We do not recommend trying to circumnavigate the laws in China.

If you need help navigating compliance and localization in China for your app on both the Apple App Store and the numerous local Android app stores, contact us today.

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