Do I Need an ISBN Licence to Release My Game in China?

01

What the licence is, and why it is called an ISBN

Every game operated commercially inside mainland China needs approval from the National Press and Publication Administration (NPPA). Games are regulated as online publications, so the approval takes the form of a publication number, which is why English-language coverage calls it an ISBN. Chinese practitioners call it the 版号 (banhao). Valve’s own documentation describes it plainly for Steam China: government approval is a prerequisite, and the Chinese publisher holds the number shown on the product page (Steamworks: Steam China).

The NPPA publishes monthly lists of approved games, separated into domestic and imported titles. Those lists name the publishing and operating entities for each game, which makes them the best public check on whether a publisher that claims to have filed imported games has actually done so (nppa.gov.cn).

02

Who can file, and what the application contains

The NPPA’s service guide for imported games sets the conditions on the applicant (NPPA service guide, October 2022, Chinese). The publishing unit must hold online publishing service qualification with an online-game scope; the copyright licence contract between the foreign rights holder and that publisher must already be registered with the National Copyright Administration; the operator must hold an ICP licence; and the game and the operator must comply with publication and minor-protection rules. Foreign investment in internet publishing is prohibited under the 2024 Negative List (China Briefing), which is why the structure is always a licence to a domestic company and never a Western studio’s own filing.

Practitioners describe three parties: the foreign rights holder (you), the publishing unit that submits and carries liability, and an operator that runs servers, user data and revenue, often the publisher or its partner (China Game Legal, February 2026). The first gate is therefore commercial, not regulatory: no signed and registered publisher contract, no filing.

The application itself, per the NPPA guide and practitioner reports, includes:

• The registered copyright licence contract and proof of the game’s copyright in its home jurisdiction.
• An overseas operating history and review report in the application form.
• At least ten colour screenshots and a demo video of no less than ten minutes.
• The full Chinese-language script plus a blocked-word list.
• Three tiers of reviewer accounts and two sets of anti-addiction test accounts, with review builds or a download link.
• An anti-addiction function description, and in practice proof of data hosting in mainland China and an ICP filing for the game’s website.

The publisher runs its own compliance review as a mock examination before submitting, so the publisher’s pre-review is the first real test the game faces.

03

How long it takes and how rare imports are

working days

80

Statutory review period from acceptance (NPPA)

months end to end

10 to 15

Practitioner reports, including one to three modification rounds (China Game Legal, 2026)

imports approved, Jan to Sep 2026

46

Against 1,525 domestic approvals (Sina Tech)

of 2026 approvals were imports

~3%

Approved in batches of three to eight a month

Western games do appear in the import lists: 2025 reportedly included Path of Exile 2, Dave the Diver, Prince of Persia: The Lost Crown and Diablo IV. The useful signal for an indie is who files them. August 2026 imports went through mid-tier provincial publishing units as well as the giants, so the realistic publisher pool is wider than Tencent and NetEase (17173, August 2026, Chinese).

04

What it costs

Official NPPA fees are nil. The costs are the publisher’s service, the legal and notarisation work, and the content changes. One lawyer-authored guide estimates publisher service fees of ¥50,000 to ¥100,000 and legal and notarisation costs of ¥30,000 to ¥80,000, and names localisation and content modification as the largest and least predictable item (China Game Legal). AppInChina quotes six to twelve months for international games (AppInChina, May 2026). These are vendor figures: quote them as estimates, and ask any publisher which of them it carries.

Then there is the money coming back. Royalties paid to a UK studio suffer 10% withholding income tax and 6% VAT withheld by the Chinese payer (China Briefing). The licence agreement should say who bears the VAT and oblige the publisher to supply tax certificates so you can claim foreign tax credit. Confirm the treaty position with your accountant; do not rely on a reduced rate a partner quotes.

05

Which routes need the licence

06

What reviewers ask studios to change

The binding law lists ten broad prohibited categories plus a minors clause. Almost everything a Western studio actually has to change is reviewer practice layered on top. Lawyers who file applications name the same recurring causes of modification notices (China Game Legal):

• Blood, corpses and skulls, usually fixable at asset level.
• In-game maps and place names, which are a red line rather than an edit.
• English text left in the interface, and a Chinese script that does not match the build.
• Missing loot box probability disclosure.
• Missing minor-protection integration: real-name login with no guest bypass, play-time limits for minors (20:00 to 21:00 on Fridays, weekends and statutory holidays under the 2021 notice) and age-band spending caps (China Law Translate).
• Political sensitivity and “misalignment with core values”, which is the judgement nobody can pre-screen.

The pattern across Western cases is consistent. Games that can be reworked at asset level get edited; games whose core is the problem (strategy maps, a China-as-villain plot) get blocked or pulled. Content added in later updates needs the same discipline as the launch build.

07

Ask the publisher for a written route

Before spending anything on a domestic release, ask the candidate to identify the publishing and operating entities, the platforms, the approval work and who is accountable for each step. A sales presentation saying “fully compliant” is not an answer to these questions:

• Which entity signs, and does it or its operator hold the online publishing service permit and an ICP licence?
• How many imported games has it filed in the last two years, and which? Check the NPPA lists.
• Which version of the game would be submitted, and what changes does it anticipate?
• What documents, rights and technical materials would we need to provide, and by when?
• Who pays for preparation, testing, revisions and ongoing updates, and is any of it recoupable from our revenue?
• What happens to the agreement, the rights and any spending if approval is delayed or refused?
• Which activities can begin before approval, and what supports that conclusion?
• Who bears the 6% VAT, and will you supply tax certificates for foreign tax credit?

Ask for the source and date behind any regulatory assurance. Then keep the timeline and budget conditional: separate preparation, application, review, revisions and platform release in the plan, and authorise each stage on its own. Our guide to choosing a China publishing partner covers the rest of the comparison.

08

What EightSix does, and does not do

EightSix does not issue approvals, submit licence applications or predict whether a game will pass. Nobody outside the reviewer and the publisher can price a probability of approval, and we will not pretend otherwise. What we do is assess whether a licensed route is worth aiming for at all, find and vet the Chinese publisher who would file, and help you negotiate a contract in which the filing work, costs and the consequences of refusal are written down.

If a proposal depends on a particular interpretation of Chinese publishing rules, obtain a current, game-specific review from counsel qualified for that jurisdiction before relying on it. Give them the proposed activities and the contract, not only the question “is Steam allowed”. That review should help you decide whether to proceed, revise the scope or stop.