Understanding China's Blockchain Information Service Filing Process

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On March 8th, the Cybersecurity Center of the Cyberspace Administration of China (CAC) held a technical exchange meeting in Shanghai focused on the filing process for blockchain information services. This session provided detailed interpretation and filing guidance for the "Blockchain Information Service Management Regulations," which were officially enacted on February 15th after being announced on January 10th. The primary goal was to assist over a hundred member units of the Shanghai Blockchain Technology Association in successfully completing their initial filings, ensuring a clear understanding of regulatory policies and supervision requirements to foster the healthy and orderly development of blockchain information services.

Key Takeaways from the Technical Exchange Meeting

Dr. Mao Hongliang delivered a keynote speech titled "Policy Interpretation and Filing Guidance for Blockchain Information Service Filing." He emphasized that accessing the filing system website requires step-by-step completion of relevant information. Formal project declaration can only occur after business operations have officially commenced.

Supported Blockchains and Filing Scope

The system currently accepts filings only for blockchain projects. It already supports mainnets such as Ethereum, Bitcoin, and EOS. Projects built on these mainnets can proceed directly with the filing process. However, user enterprises utilizing blockchain applications do not need to file. Instead, project system operators and blockchain node users are required to complete the filing.

Regarding content and code monitoring, initial registration is sufficient for now, with subsequent inspections to follow at a later stage.

Impact of Filing and Project Tracking

Dr. Mao clarified that whether a blockchain information service filing is approved or not does not directly impact the project itself. However, projects that do not pass the filing will be subject to ongoing tracking and monitoring by authorities.

Special Cases and Regulatory Considerations

For companies whose main entity is overseas but have branches or subsidiaries conducting blockchain projects within China, Dr. Mao indicated that the CAC has not yet fully considered this scenario. He mentioned that further discussion on this matter would take place after the meeting.

Additionally, projects that have issued tokens but are not yet on-chain still require filing. This includes wallet app projects. The CAC will continue to optimize relevant detailed rules and release them in subsequent updates.

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Frequently Asked Questions

What is the purpose of the Blockchain Information Service Filing?
The filing aims to provide regulatory clarity and ensure that blockchain information services operate within a defined legal framework. It helps authorities monitor and guide the healthy development of the industry while protecting users' interests.

Which blockchains are currently supported for filing?
The system supports mainnets like Ethereum, Bitcoin, and EOS. Projects built on these blockchains can proceed with the filing process directly.

Do all blockchain-related businesses need to file?
No, only project system operators and blockchain node users are required to file. User enterprises utilizing blockchain applications are exempt from this requirement.

What happens if a project does not pass the filing?
Filing approval does not directly affect the project’s operation. However, projects that fail to pass will be tracked and monitored by regulatory authorities for compliance.

Are overseas-based companies required to file?
The regulatory approach for overseas companies with branches or subsidiaries in China is still under discussion. Currently, the CAC has not finalized rules for this scenario.

Do wallet apps need to file?
Yes, wallet app projects that have issued tokens but are not yet on-chain are required to complete the filing process.