China Releases Draft Provisions for Online Platform Service Providers for Minors
Published 14 October 2025
Xia Yu
On 16 September 2025, the Cyberspace Administration of China (“CAC”) released the Draft Measures for the Determination of Online Platform Service Providers with a Massive Number of Minor Users or Significant Impact on Minors (“Draft Measures”), jointly drafted by the CAC and other relevant departments. Article 20 of the Regulations on the Protection of Minors in Cyberspace (“Regulations”) imposes six specific obligations on the online platform service providers with a massive number of minor users or significant impact on minors (“Online Platform Providers”). These include conducting periodic impact assessments, providing a minor-specific mode or section, establishing independent oversight bodies, formulating specialized platform rules, ceasing services to platform product/service providers that harm minors, and publishing corporate social responsibility report annually. The Draft Measures further specify the criteria, procedures, and operational requirements for designating the Online Platform Providers.
The Draft Measures specify the criteria for identifying the Online Platform Providers with a massive number of minor users, as well as the factors to be considered in determining the Online Platform Providers that exert significant influence on minors. The Online Platform Providers encompass various types of online product and service providers, smart terminal device manufacturers and sellers, as well as providers of new internet technologies, applications, and products. According to the Draft Measures, the online platforms with either over 10 million registered minor users or monthly active minor users exceeding one million shall be identified as the Online Platform Providers with a massive number of minor users, regardless of whether their products or services are specifically targeted at minors. Factors for determining the Online Platform Providers with significant influence on minors include: 1) substantial scale in terms of platform downloads, registered user numbers, monthly active users, or sales volume and transaction volume of online products; 2) high metrics related to minors, such as login frequency, duration of use, preference levels, and expenditure amounts; 3) the platform containing a substantial volume of information content involving or targeting minors; 4) the platform having been associated with numerous widely recognized issues concerning minors within the past three years; 5) the platform ranking highly in relevant vertical sectors.
The Draft Measures stipulate the identification procedures for the Online Platform Providers, including initiation procedures, deliberation and decision-making, and subsequent adjustments. The CAC is responsible for overall coordination of the identification process, and a dedicated Identification Advisory Committee (“Committee”) will be established to conduct specific identification tasks. In principle, identification shall be conducted every three years. Under special circumstances, such as a surge in user numbers, significantly increased impact on minors, or widespread public concern, the CAC may, upon deliberation, initiate identification procedures at its discretion. Generally, the Committee shall first propose a recommended list of entities subject to identification. After review and approval by the CAC, relevant online platform service providers will be notified to conduct self-assessments. Within 20 working days of receiving notification, they shall submit self-assessment reports. Then the Committee will solicit opinions and suggestions through forums, hearings, field visits, and other methods to draft an identification list. Based on the draft list, the CAC will determine the final identification list and publish it to the public. Objections to the identification results may be raised within 15 working days. Following the identification, the CAC will monitor the implementation of the identification. If an identified Online Platform Provider determines that it has failed to meet the identification criteria for six consecutive months, it may apply for modification of its identification status.
In conclusion, the Draft Measures delineates which online platforms shall be classified as having a massive number of minor users or significant impact on minors, thereby subjecting them to the minor protection obligations stipulated in the Regulations. Through quantitative thresholds and qualitative criteria, it precisely identifies online platforms with profound influence on minors for prioritized regulatory oversight. The Draft Measures is open for public comment until 15 October 2025.
The Draft Measures specify the criteria for identifying the Online Platform Providers with a massive number of minor users, as well as the factors to be considered in determining the Online Platform Providers that exert significant influence on minors. The Online Platform Providers encompass various types of online product and service providers, smart terminal device manufacturers and sellers, as well as providers of new internet technologies, applications, and products. According to the Draft Measures, the online platforms with either over 10 million registered minor users or monthly active minor users exceeding one million shall be identified as the Online Platform Providers with a massive number of minor users, regardless of whether their products or services are specifically targeted at minors. Factors for determining the Online Platform Providers with significant influence on minors include: 1) substantial scale in terms of platform downloads, registered user numbers, monthly active users, or sales volume and transaction volume of online products; 2) high metrics related to minors, such as login frequency, duration of use, preference levels, and expenditure amounts; 3) the platform containing a substantial volume of information content involving or targeting minors; 4) the platform having been associated with numerous widely recognized issues concerning minors within the past three years; 5) the platform ranking highly in relevant vertical sectors.
The Draft Measures stipulate the identification procedures for the Online Platform Providers, including initiation procedures, deliberation and decision-making, and subsequent adjustments. The CAC is responsible for overall coordination of the identification process, and a dedicated Identification Advisory Committee (“Committee”) will be established to conduct specific identification tasks. In principle, identification shall be conducted every three years. Under special circumstances, such as a surge in user numbers, significantly increased impact on minors, or widespread public concern, the CAC may, upon deliberation, initiate identification procedures at its discretion. Generally, the Committee shall first propose a recommended list of entities subject to identification. After review and approval by the CAC, relevant online platform service providers will be notified to conduct self-assessments. Within 20 working days of receiving notification, they shall submit self-assessment reports. Then the Committee will solicit opinions and suggestions through forums, hearings, field visits, and other methods to draft an identification list. Based on the draft list, the CAC will determine the final identification list and publish it to the public. Objections to the identification results may be raised within 15 working days. Following the identification, the CAC will monitor the implementation of the identification. If an identified Online Platform Provider determines that it has failed to meet the identification criteria for six consecutive months, it may apply for modification of its identification status.
In conclusion, the Draft Measures delineates which online platforms shall be classified as having a massive number of minor users or significant impact on minors, thereby subjecting them to the minor protection obligations stipulated in the Regulations. Through quantitative thresholds and qualitative criteria, it precisely identifies online platforms with profound influence on minors for prioritized regulatory oversight. The Draft Measures is open for public comment until 15 October 2025.