Cybersecurity Policy Report, Online Platforms Geared Toward Minors Face New Scrutiny in China, (Mar 2, 2026)
By Tony Foley
The Cyberspace Administration of China (CAC) has issued measures designed to identify online platforms that are deemed to have a “large number” of minors as users and that, as a result, must satisfy additional obligations under Chinese cybersecurity and child protection laws.
The guidance, “Measures for Identifying Network Platform Service Providers with a Large Number of Underage Users and Significant Impact on the Underage Population,” were included in a notice from the CAC on Saturday. They provide that the process of identifying impacted platforms must adhere to principles of legality, fairness, impartiality, and protecting the legitimate rights and interests of minors. The certification process is to be conducted by the State Internet Information Office in coordination with other government agencies.
Network platform service providers will be deemed to have a large number of underage users if either of the following conditions are met:
The products or services provided by the online platform are specifically targeted at minors, and the number of registered users exceeds 10 million or the number of monthly active users exceeds 1 million; or
The products or services provided by the online platform are not limited to minors, and the number of registered minor users exceeds 10 million or the number of monthly active minor users exceeds 1 million.
The rules establish the factors to be considered in identifying online platform service providers that have a significant impact on minors, including the number of downloads and users on the platform or the sales volume or transaction volume of online products, the frequency of logins, duration of use, usage preferences and spending by minors on the platform, the amount of content targeting minors, whether the platform is a representative platform in vertical fields related to minors, and the number of illegal or irregular issues faced by the platforms involving minors, among others.
The measures establish self-assessment requirements for network platform service providers. In addition, the Advisory Committee for the Recognition Work will have the power to propose that any network platform service provider that does not voluntarily apply for recognition as a covered platform be included. If an online platform fails to apply for or cooperate with the certification process, provides false materials, or conceals important facts, relevant departments, including the CAC, may bring enforcement activity in accordance with applicable laws and regulations.
As part of the identification process, opinions and suggestions will be solicited from all parties. The draft list of recommended candidates is open for public comment for no less than 30 days. The Advisory Committee for the Recognition Work will propose a list of recommended candidates based on this feedback, and the State Internet Information Office, in conjunction with relevant departments, shall conduct a comprehensive study of the proposed list of identifications, determine the list of identifications, and announce it to the public.
The measures take effect on April 1.
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