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SAPPRFT and the China Mobile Game Regulations

China’s Ministry of Culture (MOC) have been working closely with SAPPRFT (State Administration of Press, Publication, Radio, Film and Television ) and the CAC (Cyberspace Administration of China) to regulate all games that are published domestically. This regulation came into effect back in July 1, 2016, and since then many changes to the process have been made and this post is to summarize these changes.

To start, let’s explain the parties:

SAPPRFT (State Administration of Press, Publication, Radio, Film and Television)

This body regulates media in the country and are responsible for censoring anything that gets published in China.

CAC (The Cyberspace administration of China), they are the agency responsible for censorship and control over China’s Internet

MOC (Ministry of Culture), this ministry is responsible for culture policy in the country and promoting, protecting and censoring any form of cultural art.

These 3 parties effectively control all digital content that will be published in China going forward.

SAPPRFT announced in July of 2016 that all games that are to be published on the Android and iOS store in China is required to obtain the approval of the SAPPRFT administration before being released.

To obtain this approval all publishers are required to file for a Simplified Process of the Standard Process for game approval. For publishers to apple for the simplified process, their game have to meet the below requirements

  • Game copyright must be owned by domestic (Chinese) individual or entity

  • Does not contain any sensitive gameplay elements regarding politics, military, Nationality or religion

  • Have no storyline or very simple storyline

  • Considered a casual game

Now, if your game falls under the requirements, below explains the approval process.

  • Required to submit your game to SAPPRFT 20 days before the release date

  • Send 2 Smartphones with the games installed to SAPPRFT to review (Android and iOS)

  • Must have an active sim card and data plan

  • Auditors who receive the builds are given 5 days to review and if everything looks in order, they send off a recommendation letter to SAPPRFT

  • SAPPRFT will then make the final approval for on a National level. (This could take upto 10 day)

  • Upon approval the the Regional office has up to 3 day to inform the developers that the game has been approved.

  • Once the developer is informed, they have 7 days to inform SAPPRFT about their launch plan

  • And have 20 days from approval to actually launch the game or go through another series of threads to inform SAPPRFT why the game wasn’t launched.

This is the simplified process….

The Standard process is very similar to the Simplified process but the big difference is the approval time.

  • Standard Process game will take upto 3 months for an approval.

Other Notable regulations are as below:

  • Anything that violates the Chinese constitution

  • Anything that threatens China’s national unity, sovereignty, or territorial integrity.

  • Anything that harms the nation’s reputation, security, or interests.

  • Anything that instigates racial/ethnic hatred, or harms ethnic traditions and cultures.

  • Anything that violates China’s policy on religion by promoting cults or superstitions.

  • Anything that promotes or incites obscenity, drug use, violence, or gambling.

  • Anything that harms public ethics or China’s culture and traditions.

  • Anything that insults, slanders, or violates the rights of others.

  • Other content that violates the law

The actual result of this comprehensive regulation to be instilled in the Chinese Mobile space has seen a decline in the number of games that were released in China. In 2015, over 15,000 app were released on the smartphone market. Over the past 8 months since the regulation was instilled, 5,200 games have been approved and released in the Chinese market. This is a significant decrease than the previous years, and SAPPRFT is aware of this bottleneck and have publicly stated that they ‘need’ to make the approval process shorter.

One of the big concerns with these new regulations are the cost that goes along getting a single game published versus the past. It is said that it almost cost around $3,000 to $6,000 to work with a single game published now, which is enough to squeeze the out many small studios although it becomes another hurdle big publishers are going to have to deal with.

Along with the extra cost are the mandatory requirements for data and backend security the CAC has passed for any games being published in China for the protection of personal information. All games:

  • All app developers are mandated to collect real name information of the users using their app via mobile phone number or other registration methods.

  • All app developers are required to implement inspection and management systems in their app in order to stop the spread of illegal content and any content that detrimental to the Chinese Culture.

  • All App Publishers are required to keep user records for at least 60 days and report and illegal or suspicious activity to the CAC.

These regulations are being in put in place in an attempt for the Chinese Government to regulate this fast growing Mobile / App Industry. Unfortunately these regulations are costly and puts new barriers to entries for both domestic and foreign companies. The layer for censorship and controlling mass media is something China has been controlling for decades and this is just another example of China being China.

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