CAC Clarifies Filing Details, Naming Rules Take Center Stage

The Cyberspace Administration of China (CAC) has issued a unified interpretation of the filing process for blockchain information services through a Q&A document published on its official website. While the release date and issuing department are not specified, the content carries clear regulatory guidance.

Service Naming: Be Specific, Cryptocurrency Terms Prohibited

The document sets clear requirements for the "Blockchain Information Service Name." The name must clearly and concretely reflect the service's actual purpose, with no exaggeration or fabrication. It specifically mandates that service names must not include terms such as "virtual currency," "exchange," or "ICO." This rule establishes a clear naming boundary, aiming to standardize service positioning from the outset and prevent conceptual confusion or misleading claims.

Five Scenarios That Directly Impact Filing Approval

The Q&A lists five types of scenarios that will directly affect the outcome of a filing application:

  • The business involves activities related to virtual currency issuance, trading, or ICO;
  • Primary servers are deployed outside of China;
  • Necessary ICP filing has not been completed as required by Chinese regulations;
  • Submitted application materials are vague, lack key information, or contain contradictory information across different documents;
  • The service provided by the applicant does not fall within the filing scope defined by the "Blockchain Information Service Management Regulations."

Listing "virtual currency-related business" and "overseas servers" as primary concerns highlights the regulatory focus on financial risk prevention and network data security.

BaaS Platforms Explicitly Included in Filing Scope

The document provides a definitive answer to the industry question regarding Blockchain-as-a-Service (BaaS) platforms. According to the "Blockchain Information Service Management Regulations," operators that provide BaaS services such as underlying blockchain technology, node services, or存证 services to external entities must complete the filing procedure in accordance with the law. This clarification removes ambiguity for some BaaS providers and ensures comprehensive regulatory coverage.