For a commercial digital-game launch in mainland China, plan to secure a Game Publishing ISBN approval through qualified mainland publishing and operating partners. A foreign developer cannot simply buy the approval or apply for it directly, according to a September 2026 New Zealand Ministry of Foreign Affairs and Trade (MFAT) market-entry guide. The process also requires title-specific content preparation, Chinese localization, player-safety systems, and a China-specific distribution plan. This overview concerns mainland China, not Hong Kong or Macao.
What the approval is—and who applies
The Game Publishing ISBN is a publication approval number generally required for a game intended for official publication or monetization in mainland China. Despite the word “license,” it is not a commercial license that a foreign studio can purchase or apply for by itself. The MFAT guide says a foreign game company must work with a mainland China operator and an eligible Chinese publisher. The publisher submits the application through the relevant local authority; the National Press and Publication Administration (NPPA) makes the final approval decision.
NPPA’s procedure for games authorized by overseas copyright holders sets out requirements for the entities involved: the publisher must be a network publishing service unit with the relevant game scope, the copyright authorization contract must be registered, and the operating institution must hold an ICP license. Confirm the current application category and each proposed entity’s qualifications with the publisher and qualified PRC counsel. MFAT also says a Hong Kong or Macao partner cannot apply on a game’s behalf, and that having a China office or subsidiary does not let a foreign company apply directly; confirm how those points apply to your structure with counsel.
How the approval and launch process works
- Identify the publisher and operator. Vet them as separate roles. The publisher needs the relevant publishing scope and handles the filing; the operator runs the service, generates revenue, and manages ongoing compliance. MFAT says the publisher checks the operator’s ICP license and assesses the game for compliance. Ask each party to document its responsibilities before signing.
- Register the rights documents. MFAT says the foreign rights holder and Chinese operator register the software copyright certificate with the National Copyright Administration. NPPA’s imported-game procedure separately calls for registration of the copyright authorization contract. These are distinct documents: confirm ownership evidence, forms, signatories, and registration steps for your title with the local partner.
- Prepare the review-ready game and evidence. Build the submission package with the publisher against NPPA’s current procedure and its checklist for the applicable category. Materials described by MFAT and NPPA include the full game, Chinese script and other content, a demonstration video, monetization design, and evidence covering real-name registration, play-time controls, payment controls, and guest-mode settings. The precise filing materials depend on the application category.
- Submit through the publisher. MFAT describes the Chinese publisher submitting to the provincial publishing authority where it is located, which then refers the application to NPPA for final approval. Use the official NPPA procedure for the applicable category and document requirements.
- Arrange distribution after approval. Once an ISBN is obtained, the Chinese partner can coordinate distribution, store submissions, and operations. Approval does not itself place the game in stores or provide an audience; platform requirements and launch arrangements still need to be handled.
Publisher and operator: different jobs, separate checks
| Party | Role in the route described by the sources | What to verify |
|---|---|---|
| Chinese publisher | Eligible publishing entity that assesses the game and submits the application through the relevant provincial authority. NPPA’s imported-game procedure requires a network publishing service unit with the relevant game scope. | Current publishing qualification and scope, experience with overseas-rights-holder titles, responsibility for the filing, and its content-change and approval workflow. |
| Mainland operator | Runs day-to-day service and revenue generation and is responsible for continuing operational compliance. NPPA’s procedure specifies that the operating institution must hold an ICP license. | Current ICP license, operational and compliance responsibilities, platform relationships, reporting and payment mechanics, and post-launch support. |
When comparing candidates, also agree in writing on localization, any requested content changes, rights to the title, source-code access, revenue reporting, and realistic schedule assumptions. The cited guidance does not establish standard fees, revenue shares, partner performance, or the likelihood that a particular game will be approved.
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Prepare content, localization, and player safeguards
Review the whole game for content risks
MFAT says games should comply with NPPA guidance and Chinese laws and regulations. Its guide flags gambling-related content, including Mahjong and poker, drugs, organized crime, pornographic or sexual material, and politically sensitive themes as review concerns. It also describes scrutiny of cultural messaging, character design, dialogue, artistic style, and sensitive symbols. This is a guide to potential review risks, not an exhaustive statement of statutory prohibitions. Ask the proposed publisher to review the specific title and build before submission.
Localize the full experience
MFAT advises full Simplified Chinese localization, including text embedded in the environment, such as road signs, buildings, and other signage. Treat this as a content-production task, not just a translation pass over menus and dialogue: identify text and other assets throughout the game, then align changes with the publisher’s review feedback.
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The MFAT guide describes age categories of 8+, 12+, and 16+ requested during the ISBN application and assigned during review. Confirm the current rating process and how it applies to the particular title with the publisher.
Design real-name and minor protections into the service
NPPA’s notice issued August 30, 2021 (effective September 1, 2021) requires online games to connect to the national real-name anti-addiction verification system. It requires users to register and log in with valid identity information; the notice says games may not provide service to users who have not completed real-name registration and login, including through guest modes.
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Under that notice, minors may play only from 20:00 to 21:00 on Fridays, Saturdays, Sundays, and statutory holidays: one hour on each permitted day. Plan verification, account flows, and time controls around these requirements rather than treating them as features to add after approval.
Confirm data and privacy requirements for your implementation
MFAT also lists data localization for personal information, a healthy-gaming advice splash screen, and privacy policies and terms conforming to Ministry of Industry and Information Technology rules. These are consequential legal and technical questions; confirm which requirements apply to your product’s data flows and launch structure with qualified mainland counsel and the operator.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Plan for an uncertain schedule and monitor status
MFAT says NPPA does not publish approval timeframes and describes review as potentially taking from a few months to a year or longer. Treat that as a planning range, not a service commitment. The guide describes approval batches as monthly and says the public approval list is the principal status check; it notes that an application’s absence from a list usually means it remains in the queue. Ask the publisher and operator for status updates as well as checking public records.
The NPPA imported online-game approval index displayed a listing dated September 30, 2026 when checked for this article. For a particular title, consult the current imported-game index for listings, changes, or withdrawals, then verify details with the named publisher and operator. An index listing is a status reference, not a substitute for confirming the title’s operational readiness.
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Distribution is a separate workstream
MFAT says Google Play is unavailable in mainland China, Apple’s App Store requires an ISBN for mainland availability, and Huawei AppGallery and Tencent Appstore are examples of other stores. The relevant stores and their document, technical, and listing requirements can change, so confirm current requirements with each platform and the operator. Set distribution planning alongside the approval work: the ISBN is a prerequisite for the route described by the guide, not a distribution agreement or a guarantee of store placement.
Quick Recap
A practical pre-submission checklist
- Confirm that the planned launch is for mainland China and identify the correct imported-game application category.
- Verify the publisher’s relevant publishing scope and the operator’s ICP license.
- Agree on responsibilities, rights, source-code access, content changes, revenue reporting, and post-approval operations.
- Prepare the software copyright certificate and register the copyright authorization contract as required for the title.
- Complete Simplified Chinese localization across text and in-game assets, then have the publisher review content risks.
- Prepare the full build, script and other requested materials, demonstration video, and monetization information using the publisher’s current filing checklist.
- Integrate real-name verification and minor time restrictions, and resolve data, privacy, and other operational requirements with qualified counsel.
- Check the current NPPA procedure and approval index, and confirm current store requirements with the operator and platforms.
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