What Filing Actually Governs
ICP filing doesn't attach to a domain. It attaches to the entity operating a site and the network resources that site uses. The test is simple: does your service use servers or network nodes inside mainland China? If yes, filing is required; if no, it isn't.
So "does this domain have a filing" is the wrong question. A filing records a relationship — which entity, using which resources, running which site — and the domain is one field within it. That's also why filings can't be traded like domains: they record a subject, not an asset.
| Deployment | Filing required? | Notes |
|---|---|---|
| Site hosted on mainland servers | Yes | The baseline case |
| Entirely on Hong Kong or overseas nodes | Generally no | Provided no mainland nodes are used at all |
| Overseas hosting with mainland CDN nodes | Yes | Any mainland node triggers it; often missed |
| Providing paid information services | Filing plus a commercial ICP licence | Requires a valid filing number first |
| Site already live inside the mainland | Public security filing within 30 days | A separate process from ICP filing |
The table covers common scenarios. The third row is the one most often overlooked.
How Pre-Filed Domain Transactions Actually Work
There's a gap between how these transactions operate and what the regulations require. Three mechanics:
- By regulation, a different subject requires cancellation and re-application Every major cloud provider's filing documentation states it plainly: where a change of subject involves a different enterprise registration number, the original filing must be cancelled and a new application submitted. So a buyer who processes the subject change as specified no longer has that filing. Most transactions don't take that route — the filing stays under the original subject.
- Domain real-name data must match the filing subject Registry rules require the domain's real-name verification to match the filing subject. That check is the binding between subject and domain, and it's part of what a transaction has to account for.
- Verification is periodic, not continuous Authorities verify filing records periodically and cancel those that don't match. But verification runs on a cycle and samples rather than covering everything in real time — which is why many filings persist for long periods in practice. What matters is the nature of the risk: it's probabilistic, its timing is unpredictable, and when it does occur, the site going offline is borne by whoever operates it.
How Long It Actually Takes
Filing is quicker than most people assume, which is partly why the incentive to detour is weaker than it looks. There are two stages: provider pre-review, then administration review.
Per timelines published by major cloud providers, pre-review runs about 1–2 business days and administration review 1–20 business days, varying by province. In most cases the total lands inside three weeks, and often faster.
Filing also isn't a one-off. Within 30 days of a site going live, a separate public security filing is required. If paid information services are involved, a commercial ICP licence is needed too — and that can only be applied for once a valid filing number exists. Schedule all of it, or the later stages become the bottleneck.
The Compliant No-Filing Route, and Its Boundary
A service deployed entirely on Hong Kong or other overseas nodes, using no mainland servers or CDN nodes, generally requires no ICP filing. Plenty of cross-border operations run exactly this way, fully compliantly.
But the boundary matters: connecting any mainland server or CDN node triggers the requirement. This is the most commonly missed point, because people assume "hosted overseas means no filing needed" and then cross the line unintentionally by enabling mainland CDN nodes for speed. When evaluating acceleration options, this is the first thing to confirm.
Three Levels of Assessment
In practice, answer these in order:
1. Will your service use mainland nodes?
This is the only dividing line. If yes, filing is required — including when the only mainland involvement is enabling CDN nodes for speed. If no, an overseas deployment needs no filing.
2. If filing is needed, can the timeline fit the project?
Most cases complete within three weeks. The right move is scheduling it — including the window where the domain under review typically has to stay offline — rather than looking for a way around it.
3. Does your service involve paid information services?
If so, a commercial ICP licence is needed beyond the filing, and it can only be applied for once a valid filing number exists. Budget that time separately rather than discovering it when you're ready to charge.
Three Things to Confirm When Evaluating Options
Before choosing hosting or acceleration, establish these:
- Whether the plan includes mainland nodes This determines whether filing applies. Some acceleration plans enable mainland nodes by default, so ask before signing — otherwise the requirement is triggered without your knowing.
- Subject eligibility and province The filing subject must be an eligible entity or individual, and review is handled by the administration of its province, with requirements and timelines varying. Province can't be altered through the change process — moving provinces means reapplying.
- That downstream steps are scheduled too ICP filing is only the first step. The public security filing within 30 days of launch, and the commercial licence for paid services, both belong in the plan.
In Summary
The filing rule itself isn't complicated: mainland nodes mean filing; a purely overseas deployment doesn't. The market in pre-filed domains exists because of a gap between what the regulation requires — cancel and re-file — and what buyers want, which is to skip the wait. Understanding what that gap is, and who carries the risk, matters more than a simple verdict either way.
The practical approach is to schedule the filing, allowing for the window where the domain under review generally has to stay offline. If what you need is cross-border connection quality rather than mainland deployment, our CDN and overseas node options can improve latency without triggering the filing requirement.