| Scope boundary | Mobile app filing covers MIIT app filing and operational registration for mobile apps. | App personal information rules covers CAC/PIPL app governance and minimum necessary personal information collection. | Run separate scope decisions when the same launch can trigger both Mobile app filing and App personal information rules. |
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| Covered actors | Mobile app filing work is usually owned by app operator, filing owner, ICP/app distribution operations, and platform operations. | App personal information rules work is usually owned by app provider, personal information processor, privacy owner, product owner, and app store/distribution platform. | Assign separate owners when the legal route, regulator, filing, assessment, permit, or evidence package is different. |
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| Trigger event | Mobile app filing screening starts with launching or continuing a mobile app that falls within MIIT filing phases. | App personal information rules screening starts with collecting personal information through a mobile app or requesting non-necessary information for basic functions. | Record the triggering event and launch date for each route before reusing technical evidence. |
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| Core obligations | Mobile app filing requires the team to translate its official articles or measures into concrete controls for MIIT app filing and operational registration for mobile apps. | App personal-information rules require controls for CAC/PIPL app governance and minimum necessary personal information collection. | Shared facts can support both routes, but the legal conclusion and required action must be written separately. |
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| Evidence package | A defensible Mobile app filing file includes filing status, app registration details, phase timing, distribution records, and supervision response. | A defensible App personal information rules file includes app category map, basic-function data fields, consent/notice records, no-refusal review, and privacy assessment. | Reuse common documents only after each file identifies why the document satisfies that route. |
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| Timing and refresh points | Mobile app filing timing should track effective dates, filing windows, review periods, renewals, or transition dates named in its sources. | App personal information rules timing should track its own effective dates, implementation windows, reporting periods, renewals, or market-entry deadlines. | Calendar each route independently; a date in one regime does not extend or replace a date in the other. |
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| Enforcement exposure | Mobile app filing exposure usually follows the actor, regulator, and failure mode tied to launching or continuing a mobile app that falls within MIIT filing phases. | App personal information rules exposure usually follows the actor, regulator, and failure mode tied to collecting personal information through a mobile app or requesting non-necessary information for basic functions. | Preserve the evidence trail before launch, filing, transfer, procurement, sale, or disposal because later remediation is weaker than a dated decision record. |
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| Overlap and routing | Mobile app filing and App personal information rules can use the same product, app, supplier, data-flow, or equipment facts, but Mobile app filing owns the decision for MIIT app filing and operational registration for mobile apps. | App personal information rules owns the decision for CAC/PIPL app governance and minimum necessary personal information collection. | Create linked records rather than copying one conclusion across both regimes. |
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| Practical decision rule | Choose Mobile app filing when the immediate blocker is launching or continuing a mobile app that falls within MIIT filing phases. | Choose App personal information rules when the immediate blocker is collecting personal information through a mobile app or requesting non-necessary information for basic functions. | Run both tracks when the same China or cross-market launch creates both Mobile app filing and App personal information rules triggers. |
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