To publish a game commercially in mainland China, a foreign developer needs a Chinese game publishing license in the form of an ISBN issued by the National Press and Publication Administration (NPPA), and that ISBN can only be obtained through a licensed Chinese publishing partner who files the application, hosts the game on local servers, and takes on legal responsibility for its content. Foreign entities cannot apply directly. The review typically runs at least six months, covers every line of dialogue and every visual asset, and requires the game to comply with China’s minor-protection, content, and data-localization rules before an ISBN is granted.
Why a Chinese Publishing Partner Is Mandatory
Chinese law classifies video games as an internet cultural activity, a sector closed to direct foreign participation. The Administrative Provisions on Online Publishing Services bar foreign-operated entities from providing online publishing services and require any game authorized by a foreign copyright holder to be routed through a domestic publisher for review and approval. That domestic publisher must hold an Online Publishing Service Permit, and its legal representative must be a Chinese citizen residing in the country.1DigiChina. Online Publishing Service Management Rules
In practice, the relationship is a licensing arrangement. The publisher files with regulators, manages content review, and handles ongoing compliance. The developer keeps ownership of the underlying intellectual property. A copyright cooperation agreement sets the revenue split, defines the publisher’s distribution authority, and spells out who can modify content and when. The publisher must also demonstrate that it can host the game on servers physically located in mainland China, which is the only lawful place for player data to sit.
Because the publisher carries the legal liability, reputable ones run their own internal content review before anything reaches the NPPA. Service fees for shepherding an application through the bureaucracy vary widely by game complexity and the publisher’s track record, and they sit on top of the revenue share negotiated in the publishing agreement.
The Licenses and Certificates Involved
The ISBN is the headline approval, but three separate pieces of paperwork have to line up before a game can operate.
The game itself needs an ISBN from the NPPA. Nothing goes on a Chinese app store without it, and the number has to be displayed on the game’s loading screen and in marketing materials.
The entity that operates the game day-to-day needs a Commercial ICP License, formally an Internet Content Provider permit for value-added telecommunications services. Only Chinese-registered entities qualify, which is another reason the domestic-partner structure cannot be worked around.
Before an ISBN application can even be filed, the developer needs a Software Copyright Certificate from the China Copyright Protection Center under the National Copyright Administration. Registration requires the first and last 30 pages of source code, a software operation manual, and technical documentation. Standard processing runs 30 to 60 days, with expedited options available for a fee.
What NPPA Reviewers Look For in Content
Every visual asset, line of dialogue, and mechanic is reviewed before an ISBN is issued. The list of prohibited material is broad: graphic violence, religious imagery, politically sensitive themes, content that could undermine national unity, and anything reviewers judge morally inappropriate. Scripts are read word by word. Character designs and storylines that cleared every other market often need substantial rework for China.
Some game categories are simply not going to be approved. Poker and mahjong gambling titles, games with what regulators describe as “overly obscene or immoral content,” and so-called “imperial harem games” fall into this bucket. If a game’s core concept sits in a banned category, it’s worth confirming that before spending on the application.
Games with loot boxes or gacha mechanics must publicly disclose the exact probability rates for every item obtainable through the system, both on the in-game purchase screen and on the game’s official website. The transparency rule has been in force since 2017. Odds hidden in fine print draw rejections.
All text has to be accurately translated into simplified Chinese, including system messages, item descriptions, loading tips, and error prompts. Translation is treated as part of the content review, not just localization. Awkward or ambiguous phrasing that could be misread as politically sensitive has been enough to trigger rejection on its own.
Games with user-generated content, live chat, or social features carry additional obligations. Publishers must run real-time keyword filtering against government-maintained blacklists and staff human moderators to review flagged posts. Records of user-posted content, timestamps, and source IP addresses have to be retained for at least 60 days and produced to authorities on request.2Congressional-Executive Commission on China. Blocking, Filtering, and Monitoring
Minor-Protection Systems the Game Must Include
Every online game in China must integrate a real-name authentication system that checks each player’s identity against a national citizen database maintained by the Ministry of Public Security. Anonymous accounts and guest trial modes are explicitly prohibited. A game that cannot verify player identities will not get an ISBN.
Since September 2021, minors are limited to exactly one hour of online play per day, permitted only between 8:00 and 9:00 PM on Fridays, Saturdays, Sundays, and statutory public holidays. Outside those windows, no online game service of any kind may be provided to minors.3China Law Translate. Notice of Further Strict Management to Effectively Prevent Minors From Becoming Addicted to Online Games The NPPA has said it will punish operators that do not enforce the restrictions.
Spending caps run alongside the time limits:
- Under 8 years old: all payment options must be blocked entirely.
- Ages 8 to 15: single transactions capped at 50 yuan, monthly limit of 200 yuan.
- Ages 16 to 17: single transactions capped at 100 yuan, monthly limit of 400 yuan.
The caps apply across all games, not per title, so the authentication system needs to track cumulative spending and throttle purchases in real time as a minor approaches a threshold.
The Application Package
The submission is substantial, and a missing document can send the whole file back. The core package includes:
- A Game Publication Application Form detailing the developer’s history, technical specifications, monetization plan, and target audience. Forms come from the provincial NPPA branch where the Chinese publisher is registered.
- The Software Copyright Certificate.
- An authorization letter granting the Chinese publisher exclusive distribution rights within mainland China.
- The full game script in simplified Chinese, covering all dialogue, notifications, item descriptions, and menu labels.
- A catalog of every visual asset, including character skins, environmental textures, UI, and promotional art.
- Loot box and gacha probability disclosures, if applicable, listing every obtainable item and its exact drop rate.
- At least ten minutes of gameplay footage showing all major systems, menus, and monetization flows.
For mobile titles, publishers typically ship three to five pre-loaded phones with the game installed. Reviewers need unrestricted access to the full experience, including endgame content, so it is standard to provide a maximum-level test account with unlimited in-game currency. Anything a reviewer cannot reach effectively does not exist for approval purposes, and features cannot be added later without triggering another review.
How Long the Review Takes
The application moves through two stages. It first goes to the provincial NPPA branch where the publisher is registered, which checks completeness and basic compliance. From there it goes to the national NPPA office for the deeper technical and content audit.1DigiChina. Online Publishing Service Management Rules
Most of the calendar is spent at the national level. Reviewers ask for changes to code, art, dialogue, and mechanics, and the developer has a set window to respond before the application expires. Throughout, the Chinese publisher is the only party in contact with regulators. The developer never speaks with the NPPA directly, which makes the choice of publisher one of the more consequential decisions in the whole process.
Plan for a minimum of six months, and expect many applications to run longer. Imported-game approvals run at roughly nine to ten titles per month, and there is no way to pay for faster processing. Submissions involve both digital uploads to the NPPA portal and physical shipment of hardware and printed materials.
When approval comes through, the NPPA issues the ISBN and publishes the title on its monthly approval list. That public listing is the legal authorization to launch on Chinese storefronts. The ISBN must appear on the loading screen and in marketing materials; platforms will reject listings that do not display it.
Data Localization and Cross-Border Transfers
Under the Cybersecurity Law, personal information and important data collected from Chinese users must be stored on servers inside mainland China. This is why a domestic partner with local server capacity is not optional. The Personal Information Protection Law (PIPL) layers on further duties: a lawful basis for collection, data minimization, encryption and de-identification, and player rights to access, correct, and delete their information. Because real-name authentication collects data on minors, and data on minors under 14 is treated as sensitive personal information, the compliance bar sits high.
Moving player data out of China triggers additional approval. The Outbound Data Transfer Security Assessment Measures require a mandatory security assessment by the Cyberspace Administration of China (CAC) when a data handler meets any of these thresholds:4DigiChina. Translation: Outbound Data Transfer Security Assessment Measures
- Any transfer of “important data” that, if leaked or misused, could harm national security, economic operations, or public safety.
- Processing personal information on more than one million individuals and seeking to transfer personal information abroad.
- Having provided personal information of more than 100,000 people, or sensitive personal information of more than 10,000 people, abroad since January 1 of the prior year.
A game with real traction can hit the one-million-user threshold quickly, which puts a CAC assessment in play for most successful titles. Even when a formal assessment is not required, controllers must obtain separate consent from each user before any cross-border transfer and file an annual outbound transfer security report with the local CAC office. Architectures that route analytics, crash logs, or telemetry to overseas servers without going through the approval process are a common source of trouble.
Taxes on Revenue From China
Foreign developers earning royalties or licensing fees from a Chinese publishing partner face a standard withholding tax of 10 percent on gross income. This applies to royalties, dividends, interest, and other passive income sourced from China. Tax treaties can adjust the rate. For U.S.-based developers, the treaty rate for most software royalties stays at 10 percent, with a reduced 7 percent rate only for payments for the use of industrial, commercial, or scientific equipment.
Digital game sales and in-app purchases also carry a 6 percent Value-Added Tax classified under financial and modern services. The Chinese publisher normally collects and remits the VAT, but the cost flows through to the developer via the revenue split. Both the withholding tax and the VAT should be built into any financial model for a China launch, because the gap between gross Chinese revenue and what actually lands in a foreign bank account is wider than many studios expect.
Penalties for Operating Without a License
Launching in China without an ISBN is treated as a serious violation, and penalties scale with revenue. Developers who have earned more than 10,000 yuan from an unlicensed title face fines of five to ten times their total revenue from the game. Reported fines for smaller violations have ranged from 10,000 to over 700,000 yuan, with amounts trending up in recent enforcement actions.
Failures inside the approval process carry their own risks. A game that fails NPPA review three consecutive times may be permanently barred from reapplying. Publishers that miss anti-addiction implementation deadlines can lose their publishing licenses entirely, which would take down every game in their catalog, not just the one at issue. For a foreign developer, losing a publisher this way is close to a worst case: the game goes offline, revenue stops, and finding another publisher willing to inherit a tainted title is difficult.
Platforms enforce independently. Major Chinese app stores verify ISBN status before listing a game, so unlicensed titles will not appear on any legitimate storefront. Attempts to route around this through side-loading or gray-market channels risk permanent blacklisting from the Chinese market, and the NPPA keeps its own records of violations that follow a developer or publisher across the ecosystem.