CAC Opens the First Identification Round for 'Article 20' Platforms: Who Must Self-Report a Large Minor Audience, and by When

Editor’s Note — DCC.

This is the CAC’s Announcement on Carrying Out Identification of Network Platform Service Providers with a Very Large Number of Minor Users and a Significant Impact on Minors (关于开展未成年人用户数量巨大和对未成年人群体具有显著影响的网络平台服务提供者认定工作的公告). It is signed October 16, 2026, and was published on the CAC website and 网信中国 on October 19. It opens the first identification round under the Minors Platform Identification Measures, which DCC has translated in full alongside this brief.

Why it matters: identification is the switch for the heavier duties in Article 20 of the Regulations on the Protection of Minors in Cyberspace. Those duties have applied since January 2024 to platforms “with a large number of minor users or with a significant impact on minors”. Until now there was no list saying which platforms those are. This round produces one. Below, DCC calls these “Article 20 platforms”.

The announcement and its work guide are translated in full. The guide refers to two annexes (materials requirements, and provincial addresses and contacts). Neither is posted on the CAC website or in the WeChat post, and the guide says the templates are available from the local cyberspace administration. Background, the deadline count, and the reading notes are DCC’s.

The announcement in full

To further strengthen the protection of minors online and press network platforms to fulfil their primary responsibility, identification work is hereby launched in accordance with the Regulations on the Protection of Minors in Cyberspace, the Measures for Identifying Network Platform Service Providers with a Very Large Number of Minor Users and a Significant Impact on Minors, and other relevant requirements. Network platform service providers shall assess themselves on their own initiative against the identification criteria and procedural requirements, and submit application materials. Contact details, the list of application materials, and the specific requirements are set out in the Annex.

Annex: Work Guide for Identifying Network Platform Service Providers with a Very Large Number of Minor Users and a Significant Impact on Minors

Cyberspace Administration of China

October 16, 2026

The work guide in full

Work Guide for Identifying Network Platform Service Providers with a Very Large Number of Minor Users and a Significant Impact on Minors

The Measures for Identifying Network Platform Service Providers with a Very Large Number of Minor Users and a Significant Impact on Minors (the “Identification Measures”) took effect on April 1, 2026. This Guide is formulated to guide and assist network platform service providers in completing their applications in a compliant and orderly manner.

I. Scope of application

Under Articles 6 and 7 of the Identification Measures, network platform service providers in the following circumstances shall submit application materials on their own initiative and in a timely manner:

(1) To be identified as a network platform service provider with a very large number of minor users, a provider shall meet any one of the following:

1. the products or services provided by the network platform are specifically directed at minors, and it has 10 million or more registered users or 1 million or more monthly active users;
2. the products or services provided by the network platform are not limited to minors, and it has 10 million or more registered minor users or 1 million or more monthly active minor users.

(2) The identification of network platform service providers with a significant impact on minors comprehensively considers the following factors:

1. the network platform has a relatively large number of downloads or scale of users, or relatively large sales, transaction volume, or similar figures for its online products;
2. the network platform has relatively high indicators for minors’ login frequency, usage time, usage preferences, spending, and the like;
3. the network platform carries a large volume of information content involving or directed at minors;
4. the network platform is a representative platform in a minor-related vertical sector;
5. the network platform has had a relatively large number of violations of laws and regulations involving minors within the past 3 years, producing a relatively significant negative impact;
6. other factors having a significant impact on minors.

II. How to apply

Network platform service providers shall submit their identification application materials within 20 working days of the date the notice is released, by delivering written materials accompanied by an electronic version.

Method of submission: send the paper application materials (in triplicate, bearing the company seal) together with the electronic version on a CD to the provincial cyberspace administration (addresses and telephone numbers in Annex 2). Mark the envelope “[Website/platform name] + platform identification application materials”.

III. Application requirements

Network platform service providers shall act on their own initiative, carry out a self-assessment in advance as required, and prepare for identification. Where a provider meets the identification criteria but has not submitted application materials on its own initiative, the Identification Work Advisory Committee will notify it to submit them promptly.

Enterprises shall provide explanations, data, cases, and other materials in full detail in accordance with the templates, and are responsible for the completeness, truthfulness, and accuracy of the materials. Where application materials need to be supplemented or corrected, the enterprise concerned shall do so promptly as notified.

IV. Application materials

A network platform service provider applying for identification shall submit the following materials:

1. Application Letter of [XX Company] for Identification as a Network Platform Service Provider with a Very Large Number of Minor Users and a Significant Impact on Minors;
2. Network Platform Service Provider Information Sheet;
3. Self-Assessment Report of a Network Platform Service Provider with a Very Large Number of Minor Users and a Significant Impact on Minors, covering at least: the platform’s basic information; user scale and the share of minor users; an analysis of minors’ use; the self-assessment conclusion on the platform’s impact on minors; and the minors-protection measures already taken;
4. Letter of Undertaking;
5. other supporting materials.

Network platform service providers are responsible for the completeness, truthfulness, and accuracy of the self-assessment report and materials submitted, and shall provide necessary explanations and other supplementary materials as required. They shall not include false information, misleading statements, material omissions, or the like. Templates for the relevant materials may be obtained from the local cyberspace administration.

Annexes: 1. Application Materials Requirements for Network Platform Service Providers with a Very Large Number of Minor Users and a Significant Impact on Minors

2. Addresses and Contact Details for Receipt of Materials

What identification triggers

DCC context. The guide is procedural; the stakes sit in the Regulations. Under the first paragraph of Article 20, an Article 20 platform must:

1. consider minors’ physical and mental development at the design, R&D, and operation stages, and regularly assess its impact on minors’ online protection;
2. provide a minors’ mode or a dedicated minors’ zone;
3. build a minors-online-protection compliance system, and set up an independent body made up mainly of external members to supervise it;
4. adopt platform rules that set out the minors-protection obligations of the businesses operating on the platform, and prominently tell minor users of their rights and remedies;
5. stop serving on-platform businesses that violate laws or administrative regulations, seriously harm minors’ physical and mental health, or infringe their other lawful rights and interests;
6. publish an annual social responsibility report on minors’ online protection.

Article 54 sets the penalties. A breach of any of these duties draws an order to correct, a warning, and confiscation of illegal gains. Refusal to correct adds a fine of up to RMB 1 million on the platform and RMB 10,000 to 100,000 on the people responsible. Where a breach of duty 1 or 5 has serious circumstances, provincial-level or higher authorities can fine up to RMB 50 million or 5% of the previous year’s turnover, suspend the relevant business or order a suspension for rectification, and refer the platform for revocation of permits or licenses. They can also fine the responsible people RMB 100,000 to 1 million and bar them from senior roles for a period.

One more duty is in draft. The State Council Provisions on Ensuring Minors’ Healthy and Safe Use of the Internet, released by the CAC for public comment on September 18, 2026, would require Article 20 platforms to file with the national cyberspace administration through the provincial office, and to report on how their minors’ mode is built and used. Cyberspace authorities would verify those filings annually. It is a draft and not in force.

How the round runs

The deadline, on DCC’s count. The guide runs the 20 working days “from the date the notice is released”. If that is the October 16 date the announcement bears, the last day is Friday, November 13, 2026. If it is the October 19 date the CAC published it, the last day is Monday, November 16, 2026. There is no public holiday in between. The guide does not say which date counts, so the safer working date is November 13.

Reading notes for platforms with Chinese minor users

• Meeting the Article 6 numbers means filing. The Measures say a platform that meets the criteria “shall” apply on its own initiative. A platform that does not file can still be pulled in by notice (Art 10). Failing to apply or cooperate, or filing false materials, is dealt with “in accordance with the relevant laws and regulations” (Art 11). Neither the Measures nor the guide sets a separate penalty.
• Counting minors is the hard part. A general-audience platform has to report “registered minor users” and “monthly active minor users”. Neither the Measures nor the guide says how to count them, or how to define a monthly active user. Real-name and age-verification data is the obvious source. The report is only as credible as the counting method behind it, so document the method.
• Article 7 has no numbers. The impact test is discretionary. A platform below the Article 6 thresholds can still be identified if it leads a minor-related vertical (education, gaming, youth content), if minors spend heavily or long on it, or if it has a record of violations involving minors. The guide asks platforms in either category to file.
• The self-assessment report is evidence. It must state the share of minor users, analyze minors’ use, and list the protection measures already taken. It goes to the regulator under a signed undertaking that it is complete, true, and accurate. Write it as a record that may be checked against the platform’s own data later.
• No carve-out by ownership. The Measures do not distinguish between domestic and foreign-invested operators. Any network platform service provider with this scale of minor users in China is in scope.
• Filing is local and on paper. Materials go to the provincial cyberspace administration, in triplicate, under company seal, with a CD. Get the templates and Annex 2 contacts from the local office now. They are not online.

— 国家互联网信息办公室 (Cyberspace Administration of China), 关于开展未成年人用户数量巨大和对未成年人群体具有显著影响的网络平台服务提供者认定工作的公告 (Announcement on Carrying Out Identification of Network Platform Service Providers with a Very Large Number of Minor Users and a Significant Impact on Minors), with the attached Work Guide, signed October 16, 2026, published October 19, 2026 via 网信中国 and the CAC website. Original (Chinese).

The deadline dates are DCC’s count, not the CAC’s. The guide’s two annexes were not published and are not covered here. The Chinese original is authoritative.

— Not legal advice.