---
title: "CAC Opens the First Identification Round for 'Article 20' Platforms: Who Must Self-Report a Large Minor Audience, and by When"
author: "DCC Editorial"
published: 2026-10-20T12:00:00.000Z
url: https://datacompliancechina.com/posts/cac-minors-platform-identification-launch-october-2026/
description: "On October 16, 2026, the Cyberspace Administration of China (CAC) launched the first round of identification under the Measures for Identifying Network Platform Service Providers with a Very Large Number of Minor Users and a Significant Impact on Minors (国信办发文〔2026〕2号, effective April 1, 2026). DCC translates the announcement and its work guide in full. Platforms that meet the numeric thresholds must self-assess and file within 20 working days, which on DCC's count lands in mid-November 2026. The thresholds are 10 million registered or 1 million monthly active users for minor-directed services, and 10 million registered or 1 million monthly active minor users for general-audience services. Platforms caught by a six-factor impact test are expected to file too. Paper filings go to the provincial cyberspace administration. Platforms on the final list take on the extra duties of Article 20 of the Regulations on the Protection of Minors in Cyberspace: minors-impact assessments, a minors' mode, an independent external supervisory body, platform rules, and an annual social responsibility report. For serious breaches of two of them (the impact assessment, and cutting off harmful on-platform businesses), Article 54 allows fines of up to RMB 50 million or 5% of the previous year's turnover."
tags: ["minors", "minors-protection", "cac", "platform-obligations", "self-assessment", "minors-online-protection-regulations"]
laws_cited: ["minors-platform-identification-measures", "minors-online-protection-regulations", "minors-healthy-safe-internet-use-provisions-draft"]
domains: ["minors-protection", "personal-information", "app-compliance"]
account: "wangxin-china"
original_title: "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"
original_author: "国家互联网信息办公室 (Cyberspace Administration of China)"
original_publication: "网信中国 WeChat Official Account"
original_url: "https://mp.weixin.qq.com/s/5XHoAVMO4oWWPzOp7ySQ7w"
source_language: "zh"
---

> **Source: Data Compliance China** — https://datacompliancechina.com/posts/cac-minors-platform-identification-launch-october-2026/ · China data law, translated and annotated for overseas counsel. Cite as: Data Compliance China, "CAC Opens the First Identification Round for 'Article 20' Platforms: Who Must Self-Report a Large Minor Audience, and by When", https://datacompliancechina.com/posts/cac-minors-platform-identification-launch-october-2026/
> *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](/laws/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](/laws/minors-online-protection-regulations/).
> 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](/laws/minors-online-protection-regulations/), 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*](/laws/minors-healthy-safe-internet-use-provisions-draft/),
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

| Step | Rule | Timing |
|---|---|---|
| Launch | Measures Art 8; this announcement | Signed October 16, 2026; published October 19 |
| Self-assessment and application | Measures Arts 4, 9; Guide II | 20 working days from release of the notice |
| Notice to platforms that did not apply | Measures Art 10; Guide III | Self-assessment due 20 working days after the notice is received |
| Consultation | Measures Art 12 | Symposiums, expert meetings, site visits |
| Proposed list | Measures Arts 12–13 | Public comment, generally at least 30 days |
| Final list | Measures Art 14 | Published by the CAC with the other departments |
| Exit | Measures Art 16 | Application after 6 consecutive months below the criteria |
| Next round | Measures Art 8 | In principle every 3 years, or earlier if user numbers surge |

**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](https://www.cac.gov.cn/2026-10/19/c_1794086281588959.htm).
[Original (Chinese).](https://mp.weixin.qq.com/s/5XHoAVMO4oWWPzOp7ySQ7w)*

*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.