At Gandi, we currently offer over 750 TLDs (probably the one with the most coverage in the industry), so we often see policy changes firsthand.
One of these changes was the introduction of new laws in China and new regulations by MIIT (China’s Ministry of Industry and Information Technology) at the end of 2017. We have informed our customers of these new regulations to hopefully avoid some confusion, and I’d like to share them here as well.
Gandi has been accredited by the CNNIC since 2015, which allows us to sell .CN domains (China’s national top-level domain) to our customers around the world.
At CNNIC, we are listed as an overseas registrar. As you probably know, owning a .CN domain name requires that the domain name contain the real name of the holder and must also pass an additional verification process by the CNNIC (using the owner’s passport or ID). ). This process has not changed. CNNIC has been under MIIT for a few years now. But that doesn’t necessarily mean that Gandi is now a so-called “MIIT-accredited registrar” (yet), although we can support you perfectly in Chinese thanks to our team in Taipei.
If you are not hosting data in China (i.e. using a Gandi VPS or our PaaS outside of China), no additional steps are required to register your .CN domain name.
However, if you intend to host your data with a cloud hosting provider in China (and sell to customers in China), they may require you to transfer your domain name to an office registration accredited by MIIT. Only companies in China can currently become a “MIIT Accredited Registrar”. Gandi does not have an office in China, so we are not accredited by MIIT.
We are however in the process of checking with the CNNIC if this policy can be modified. Please note that the domain owner must also be a legal entity in China (or a Chinese resident) if you are hosting data in China.
A domain name must then undergo what is called an ICP verification (ICP Filling or ICP License depending on usage).
Although MIIT has removed the clause specifying that the registrar must be in China from the draft new Chinese cyberspace regulations, local MIIT offices (which perform PKI verification) can still insist that your registrar registration that uses your domain name is in China. It’s strange because many registrars in China don’t offer all top-level domain names, let alone all the additional services provided by Gandi such as DNSSEC, global DNS infrastructure, and services such as Gandi Mail and Web Forwarding. Also, not all top-level domain names offer real-name verification. So the process to get your license or ICP filling can be quite complicated from now on.
Mandatory real name verification also applies to .COM and other domain names (which until then were technically not legal to use in China, although Baidu.com, Taobao.com use a . COM). CNNIC has an agreement with Verisign (.COM & .NET) to allow them.
Given the information above, we currently recommend the following:
- If you intend to sell to customers in China on your website with a Chinese IP address, make sure the owner’s contacts are with your partner in China
- If you’re still having trouble with ICP fill or ICP license requests, you’ll need to transfer your domain to a national registrar. Laws in China change often and I hope these restrictions will be lifted soon
- Otherwise, don’t use a China hosting provider, but understand the risk of your website being blocked if it contains sensitive or harmful material (nb the definition can be very broad)
- Use several consultants to register your ICP license or perform your ICP filling. Rules vary by province!
Did you encounter any problems while using your domain name in China? We would love to hear from you during your comments[at]gandi.net.
You can also contact me on Linkedin or via CircleID.