Privacy & Information Security Law Blog

On September 16, 2025, the Cyberspace Administration of China (“CAC”) issued the draft Measures for the Identification of Online Platform Service Providers with a Substantial Number of Minor Users and Significant Influence on Minors (the “Draft Measures”). The Draft Measures propose the rules for identifying online platform service providers that should be subject to the substantial compliance obligations related to minors, as stipulated by the Regulations on the Protection of Minors Online (the “Regulations”) which took effect in China in January 2024. In China, a minor is any individual aged 14 and below.

Standards for Identifying Providers

According to the Draft Measures, if either of the following conditions are met, the online platform service provider would be deemed as having a substantial number of minor users (i.e., a Type 1 Provider):

• the products or services it provides are specifically targeted at minors, with more than 10 million registered users or more than 1 million monthly active users; or
• the products or services it provides are not specifically targeted at minors, but the number of registered minor users exceeds 10 million, or the number of monthly active minor users exceeds 1 million.

In addition, the Draft Measures also include the following factors to be considered when determining whether an online platform service provider has significant influence on minors (i.e., a Type 2 Provider):

• the platform has a large number of downloads, registered users or monthly active users, or the provider’s online products have a large volume of sales or transactions;
• the platform shows high indicators with respect to the frequency of logins by minors, duration of use by minors, preferences of minors or amount of expenditure by minors;
• the platform contains a large amount of information or content involving or targeting minors;
• within the past three years, the platform has experienced a considerable number of prominent incidents involving minors, has violated law or regulation in a serious manner, and has attracted widespread public attention;
• the platform ranks highly in relevant sectors, for example as an online education platform or online gaming platform; and
• any other factors that indicate that the platform has significant influence on minors.

Type 1 Providers and Type 2 Providers are hereinafter referred to together as the “Providers.”

Procedure for Identifying Providers

According to the Draft Measures, the Recognition Advisory Committee (the “Committee”) will prepare a draft list of Providers to be reviewed by the CAC. Following such, the Committee will notify the listed Providers that they are required to conduct and submit a self-assessment within 20 business days of receipt. The draft list of Providers will also be subject to public comment. The CAC, along with the relevant authorities, will then publish the final list of Providers. The listed Providers will have the right to raise an objection for being listed within 15 business days of publication of the list.

It is proposed in the Draft Measures that the CAC will conduct the procedure for identifying Providers every three years. However, the procedure may be initiated at any time if there is a surge in users of an online platform, a significant increase in influence on minors through an online platform, or widespread public concern regarding an online platform.

Next Steps

The Draft Measures are open to public comment until October 15, 2025.