China: China SAPPRFT Issued Implementation Rules To Streamline The Approval Process Of Mobile Games

Last Updated: 20 January 2017
Article by Tracey Tang
Most Read Contributor in China, October 2017


  • From July 1, 2016, no mobile game can be published without pre-approval from the SAPPRFT.
  • A simplified approval process which is expected to complete within 18 working days will be applicable to qualified domestic games.
  • More holders of Online Publishing License will take part in the mobile game ecosystem and revenue share.

On June 2, 2016, the State Administration of Press, Publication, Radio, Film and Television ("SAPPRFT", "国家新闻出版广电总局") promulgated the Notice on the Administration of Publishing Services of Mobile Games ("Notice", 《关于移动游戏出版服务管理的通知》) to set out the pre-approval requirements of publishing mobile games in China. The Notice will take effect on July 1, 2016 and will be applicable to any mobile game published in China, regardless of the game genre, origin or the platforms to be distributed (Android or iOS). At present, only around 5% of mobile games in the market are reportedly compliant with such requirements and the existing games without the SAPPRFT approval will have to be shut down if the relevant application can not be filed before October 1, 2016. As the first set of specific guidelines to detail the implementation of the Regulations on the Administration of Online Publishing Services ("Regulations",《网络出版服务管理规定》), the issuance of the Notice indicates the full attention of the regulatory body to the fast growing and lucrative mobile game industry.

In line with the Regulations, the Notice mandates each mobile game should have a "Game Publishing Service Entity (游戏出版服务单位)" ("Publishing Entity"), holder of Online Publishing Service License ("Online Publishing License", 网络出版服务许可) with online game publishing scope granted by the SAPPRFT, to take full responsibility for game content review and examination as well as the application for the SAPPRFT's pre-approval prior to game publishing.

The Notice introduced a simplified approval process where the Publishing Entity is only required to submit a standard application form to provincial branch of the SAPPRFT at least 20 working days prior to the contemplated game launch date. The simplified process is applicable to mobile games that meet the following criteria (i) game copyright is owned by domestic individuals or entities, (ii) they do not contain any sensitive elements such as politics, military, nationality or religion, (iii) they have no storyline at all or only have a very simple storyline, and (iv) they are in the genres of casual games covering match-three, endless runner, top down shooter, board, puzzle, sports, music and etc. The simplified approval process, including the review of the completeness and accuracy of application information by the provincial branch of the SAPPRFT, the grant of approval by the SAPPRFT and the notification of the approval result by the provincial branch of the SAPPRFT, can be completed within around 18 working days if all required information is duly provided in the first place. The game can only be launched after the SAPPRFT has issued the approval. Within 7 working days following the game launch, the Publishing Entity shall report to the provincial branch of the SAPPRFT game operation information including the launch date, where to download the game, Operating Entity and whether in-app purchase is made available and etc. However, if the game launch is delayed more than 20 working days as originally planned, the Publishing Entity shall provide written explanations to the SAPPRFT.

For foreign copyrighted mobile games, the Publishing Entity shall follow the currently applicable approval requirements under which the required information is more complicated. For domestic mobile games do not satisfy the standards for the simplified process, the requirements and process are largely similar to those applicable to foreign games. The SAPPRFT sets no timeline for such process but usually it may take as long as 3-5 months from filing the application to obtaining the approval.

The Publishing Entity, as the applicant for the SAPPRFT approval and the ultimate responsible party for game content, shall closely supervise the game operation, including its regular updates. In case of any change to the Publishing Entity, game name or Operating Entity, the Publishing Entity shall submit such changes to the provincial branch of the SAPPRFT which will then report to the SAPPRFT for updating the existing approval. Any new version, updated version or new derivative introducing significant changes to the approved game will be regarded as a new game and its publishing shall be subject to a separate approval process.

The "Operating Entity" of a mobile game presumably refers to the party/parties responsible for the commercial operation of the game (including the distribution of the game to different APP stores, the collection of data and the payment from the players, and etc). The Notice permits a mobile game's Operating Entity can be separate from the Publishing Entity while in practice one entity usually takes up two roles as long as it holds both Online Publishing License and ICP License. As far as small or middle size game developers or operators are concerned, it is quite challenging for them to apply or maintain Online Publishing License or ICP License, however, they usually have to take a leading role in the commercial operation of the games including distribution, marketing, monetization and etc. Apparently the regulatory body would love to see more and more holders of Online Publishing License will act as the Publishing Entities of existing or future games and therefore participate the ecosystem and revenue share of mobile game operation. In particular, assuming there are only a limited number of Online Publishing License holders in the market, the cost of engaging a Publishing Entity to get approval from the SAPPRFT will continue going up.

Though the Notice presents no major regulatory changes to the publishing of foreign mobile games in China, foreign developers or publishers shall be alert that it is another strong signal that China government keeps strengthening the administration of mobile game industry.

First published on June 7, 2016.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

Some comments from our readers…
“The articles are extremely timely and highly applicable”
“I often find critical information not available elsewhere”
“As in-house counsel, Mondaq’s service is of great value”

Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


From time to time Mondaq may send you emails promoting Mondaq services including new services. You may opt out of receiving such emails by clicking below.

*** If you do not wish to receive any future announcements of services offered by Mondaq you may opt out by clicking here .


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at and we will use commercially reasonable efforts to determine and correct the problem promptly.