Notice on China’s Recent Legislation on Mobile Gaming

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On June 2, 2016, China’s State Administration of Press, Publication, Radio, Film and Television (SAPPRFT) bureau issued a “Notice” titled Circular on the Administration of Mobile Game Publishing Service, which states that all online publications and mobile games must be approved by the SAPPRFT. The Notice, which went into effect on July 1, 2016, has spawned numerous legal gestures and created heated discussions within the mobile gaming community in China and around the world. The stakes are high for mobile game developers looking to profit in the Chinese market and there is still uncertainty on the impact the Notice will have on the industry as a whole.

These new regulations have prompted many app developers to hire independent third party experts to better understand the approval process set forth by the SAPPRFT. Appcoach has also consulted many industry experts on the Notice and the impact it will have on the business. After a thorough analysis of the text, we believe there are three key points to be aware of:

  1. SAPPRFT applies only to Chinese publishers with no specific mention of overseas clients. We believe the level of impact on publishers outside of China will be negligible. Oversea publishers should take a “wait and see” approach. No one can be certain whether the App Store approval process in China may take longer or not. It is also too soon to judge the impact of the Notice on oversea publishers. 
  2. The main “rule” and impact of the Notice states that mobile games will be approved by the SAPPRFT in the same manner PC games have in the past. Before a mobile game can be published and available for download, the developer must obtain a government issued license.
  3. The Notice categorizes games into two groups: 1) Games which do not involve “politics, army, ethics, and religion” as well as “simplified” games such as solitaire, chess, puzzles, sports, music, dance and other casual games. And 2) games which have political or religious themes.

This Notice specifies 20 working days. However, according to SAPPRFT, the typical approval time for PC games has been anywhere between three weeks and three months – app developers should plan accordingly. Appcoach has assembled a brief Q&A to help answer some questions you may have.

Q: Which platforms and app stores will be affected?

A: This will affect the App Store on all devices. Updates and approvals for mobile games in China will be prolonged.

Q: What can publishers outside of China expect from this legislation?

A: There is no mention of an approval timeline or an app submission procedure in the Notice for publishers with headquarters outside of China.

Q: The Notice states that the approval process takes a maximum of 18 working days from submission to approval – is that correct?

A: Yes. The timeline stated in the Notice only refers to the first category (games without political and/or religious themes). 


The article is based on Appcoach’s interpretation of the existing SAPPRFT regulation. Appcoach consulted both industry experts and third party research. Thus, the interpretation is not equivalent to the actual implementation of the regulation. Due to various factors, the specific implementation of the legislation may differ from what is mentioned in this article.

About Appcoach

Founded in May 2014 as a global media agency, Appcoach opened its first office in Shanghai, China. In early 2015, Appcoach expanded westward opening offices in San Francisco and London. Today, Appcoach has a global presence with offices located nine cities in seven countries: China (Shanghai, Beijing, Shenzhen, Guangzhou), USA (San Francisco), UK (London), India (Mumbai), Indonesia (Jakarta), and Singapore.

Appcoach consults China-based clients on how to expand their global market and channels, as well as international clients to integrate local resources worldwide. Appcoach’s coherent and principled globalization characteristics has allowed the company to rapidly gain access to global digital marketing resources. Appcoach's machine intelligence, widespread data centers and human touch deliver premium, technology-supported solutions that maximize user acquisition. Their global presence combined with local knowledge, mobile marketing strategy, and first class optimization has enabled them to work with over 1,000 advertisers and 400 media partners. Appcoach has successfully launched 500 apps in 150 countries.