For a commercial digital-game launch in mainland China, plan on obtaining a Game Publishing ISBN approval through qualified Chinese publishing and operating partners. A foreign developer or rights holder cannot apply for it directly under the route described by New Zealand’s Ministry of Foreign Affairs and Trade (MFAT) in its September 2026 market-entry guide. The approval process, content preparation, player-safeguard integration, and China-specific distribution all need to be part of the launch plan—not tasks to leave until after the game is finished.
This guide concerns mainland China, not Hong Kong or Macao. The applicable filing category and requirements depend on the game and its proposed service; confirm them with the prospective publisher, operator, and qualified mainland counsel.
What the game approval covers
The Game Publishing ISBN is a publication approval number for a game intended for official publication or monetization in mainland China. It is not a commercial licence that a foreign studio can simply buy or apply for on its own. According to MFAT, a foreign company needs a mainland Chinese partner to pursue the approval. MFAT also says a foreign company’s China office or subsidiary, and a Hong Kong or Macao partner, cannot apply on the game’s behalf; confirm how those structures affect a specific deal with qualified PRC counsel.
The process has two distinct local roles: an eligible Chinese publisher submits the application, while a mainland operator handles the game’s ongoing service and compliance. NPPA’s procedure for games authorized by overseas copyright holders sets out requirements for both entities. Do not treat a proposed publishing or distribution deal as proof that either party qualifies.
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Choose and verify the publisher and operator
Check the publisher’s authority
NPPA’s imported-game procedure calls for a network publishing service unit with the relevant game-publishing scope. MFAT says the eligible publisher is generally a state-owned organization. The publisher checks the operator’s ICP license and assesses the game for compliance before submitting it through the applicable channel. Ask the proposed publisher to confirm its qualifications and the current application route for this title.
Check the operator’s role and licence
The operating institution must hold an ICP license under NPPA’s procedure. MFAT describes the operator as responsible for day-to-day operations, revenue generation, and continuing regulatory compliance. Confirm which company will actually operate the service, which entity holds the relevant licence, and who is accountable for obligations after approval.
Put responsibilities in writing
Before committing the rights or a production schedule, agree who controls each filing and launch task. Compare prospective partners on:
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- Eligibility, publishing scope, and experience with imported games in the intended platform category.
- Responsibility for the application, localization, content changes, technical integration, operations, and ongoing compliance.
- Rights to the game, access to source code and submission materials, and approval rights over changes.
- Revenue reporting, payment mechanics, distribution relationships, and support after approval.
- The assumptions behind the proposed schedule, including time for revisions and regulatory review.
The cited government guidance does not establish standard revenue shares, market pricing, partner performance, or the likelihood that a particular title will be approved. Negotiate those matters on their own evidence and terms.
Prepare rights documents and the submission build
Keep the copyright records distinct
MFAT says the foreign rights holder and Chinese operator register the software copyright certificate with China’s National Copyright Administration. Separately, NPPA’s imported-game procedure lists registration of the copyright authorization contract for a game whose rights holder is overseas. These are different documents and steps: ask the partner to confirm the ownership evidence, contract form, and registration requirements for the title rather than assuming one record replaces the other.
Build a review-ready package
MFAT’s general checklist includes a full game build; complete scripts, text, video, and assets; monetization design; real-name authentication integration; and anti-addiction mechanisms. NPPA’s imported-game procedure calls for extensive Chinese-language materials, including the full Chinese script and a demonstration video, as well as evidence for real-name registration, time controls, payment controls, and guest-mode settings.
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Requirements vary by application category. The publisher should give the team the current official checklist and identify which build and evidence are required for this application. Treat the submitted build, its Chinese text, monetization design, and safeguard behavior as a coordinated package: changes to one can affect the materials or implementation represented in another.
Review content and localize for the mainland release
Assess content before submission
MFAT says a title should comply with NPPA guidance and Chinese laws and regulations. Its guide flags gambling—including Mahjong and poker—drugs, organized crime, pornographic or sexual content, and politically sensitive material as potential concerns. It also describes review of cultural messaging, character design, dialogue, art style, and sensitive symbols. These are examples of review risks, not a complete statement of statutory rules. Have the local publisher review the specific game and identify changes before filing.
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MFAT advises full Simplified Chinese localization, including words visible in the world, such as text on road signs, buildings, and other signage. Include interface text, narrative, promotional or tutorial material, and other player-facing text in the localization review. The guide describes age categories of 8+, 12+, and 16+, with a rating requested during the ISBN application and assigned during review. Confirm the current process and how non-text content is treated with the publisher.
Design identity checks and protections for minors
NPPA’s August 30, 2021 notice, effective September 1, 2021, requires online games to connect to the national real-name anti-addiction verification system. Players must register and log in with valid identity information; the notice says services cannot be provided to users who have not completed real-name registration and login, including through guest mode.
Under that notice, minors may play only from 20:00 to 21:00 on Fridays, Saturdays, Sundays, and statutory holidays, for one hour on each permitted day. These are regulatory limits, not suggested settings. Work with the operator to implement and demonstrate identity verification, access and time controls, and any required payment controls in the service and submission evidence.
MFAT also flags personal-information data localization, a healthy-gaming advice splash screen, and privacy policies and terms that conform to MIIT rules. Those points can depend on the product’s data flows and launch structure; confirm the applicable obligations with qualified mainland counsel and the operator before designing the service.
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Submit through the Chinese publisher
- Confirm the application category and checklist. Have the qualified publisher identify the applicable NPPA procedure and current required materials for the game.
- Complete the rights and partner documentation. Coordinate the software copyright certificate, registered authorization contract, publisher qualifications, and operator’s ICP license evidence.
- Finalize the Chinese materials and build. Assemble the review-ready game, full Chinese script and other content, demonstration video, monetization details, and evidence of player safeguards required for the category.
- Submit through the publisher. MFAT describes the publisher submitting to the provincial publishing authority where it is located, followed by referral to NPPA for final approval. NPPA’s procedure is the controlling reference for the filing category and document specifics.
Do not treat a general launch checklist as a filing form: the publisher should verify the current requirements for the actual application.
Plan for an uncertain review period
MFAT says NPPA does not publish approval timeframes and that review can take from a few months to a year or longer. That is a planning range, not a service-level commitment. Build time into the schedule for localization, document preparation, partner review, and possible changes; avoid making a mainland release date depend on an assumed approval month.
MFAT describes approval batches as monthly and identifies NPPA’s public approval list as the main way to check status. The guide says that absence from a list usually means an application remains in the queue. The NPPA imported online game approval index displayed a listing dated September 30, 2026 when checked for this article; check the current index for title-specific status and any later changes or withdrawals, then verify the position with the named publisher and operator.
Arrange distribution after approval
An ISBN is an approval step, not a distribution plan. MFAT says the Chinese partner can arrange distribution after approval. Google Play is unavailable in mainland China; Apple’s App Store requires an ISBN for mainland availability. Huawei AppGallery and Tencent Appstore are examples of other stores identified by MFAT. Confirm current listing documents, technical requirements, and availability directly with the operator and each intended platform.
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Agree in advance who will manage store submissions, updates, customer operations, revenue reporting, and compliance after launch. Store acceptance and partner distribution arrangements are separate from NPPA approval.
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Practical launch checklist
- Confirm that the target is mainland China and identify the intended commercial model and application category.
- Verify the publisher’s relevant publishing scope and the operating institution’s ICP license.
- Agree in writing on filing, rights, localization, technical integration, operations, distribution, and continuing compliance responsibilities.
- Register the software copyright certificate and the overseas-rights authorization contract as separately applicable requirements.
- Complete a title-specific content review and prepare the full Simplified Chinese experience and review materials.
- Integrate and document real-name verification, minor time controls, and relevant payment and guest-mode settings.
- Submit through the publisher, track the public NPPA list, and confirm status with both local partners.
- After approval, coordinate platform listings and ongoing operations with the operator.
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