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QuestionChina

Do preinstalled mobile apps have special China requirements? Direct answer

Yes. A manufacturer of a covered must control which apps are preinstalled, disclose them, make non-basic apps uninstallable, prevent removed apps from returning after an operating-system upgrade, and keep the approved software configuration consistent.

The rules apply to products that connect to a public mobile communications network, have an operating system, and let users install and uninstall apps. Separate duties apply to app-distribution platforms and billing providers.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Oct 15, 2026
2 sections2 primary sources
Overview

Yes, if the product is a : a mobile communications terminal that connects to a public mobile communications network, has an operating system, and lets users install and uninstall apps. Manufacturers must disclose preinstalled apps, make every app outside the limited basic-function categories uninstallable, prevent removed apps from being forced back during an operating-system upgrade, and keep the preinstalled-app configuration consistent before and after network access approval. App stores, other distribution platforms, and billing providers have additional duties that do not automatically attach to every terminal manufacturer.

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2 of 2 questions
Question 1

Short answer

A covered manufacturer must list preinstalled apps in the product instructions and show, in the instructions or on the outer packaging, how users can find detailed app information. The disclosed information includes the app name, function, uninstall method, developer, required permissions, and the content, purpose, method, and scope of personal-information collection and use.

The manufacturer and app provider may not use terminal functions unrelated to the service or send unlawful commercial messages. Collection or use of personal information, starting an app, or bundling another app requires clear notice and user consent under the provisions effective from 1 July 2017. Other privacy and app-service rules may impose additional requirements.

  • From 1 January 2023, is limited to system settings and file management; multimedia capture; calls, text messages, contacts and browser; and the app store. At most one for each basic function may be non-uninstallable.
  • All other preinstalled apps must have a safe and convenient uninstall method. Associated resource, configuration and user-data files must also be removable when removal does not impair safe terminal use.
  • The manufacturer must prevent a user-removed from being forced back during an operating-system upgrade and must take measures against operating-system replacement or unauthorized app installation in distribution channels.
Question 2

Separate manufacturer and platform duties

The 2022 notice requires terminal manufacturers to register, review, monitor, retain and remove preinstalled apps throughout their life cycle, alongside disclosure, complaints and personal-information protection. Separately, Article 8 of the 2016 provisions assigns the detailed distribution-platform duties both to platform service providers and to manufacturers that preinstall a distribution platform: register provider, operator and developer identities; review, test and monitor apps; remove unlawful or malicious apps; disclose permissions; and handle complaints. For that distribution activity, retain the app and version, release time, function, purpose, MD5 checksum (a file fingerprint) and server-access information for at least 60 days.

The five-month record period is narrower: it applies to a company that bills on behalf of a mobile app and covers user confirmation information and original billing data. It is not a general five-month retention rule for every manufacturer or app platform.

  • Manufacturer file: model and software-build identifier, controlled preinstalled-app inventory, app-detail disclosure, user notice and consent flows, uninstall tests, upgrade non-restoration tests, and channel-control measures.
  • Network-access file: the declaration supplied with the mobile-terminal application, evidence that preinstalled software is consistent before and after approval, and the decision and record for any newly added app or major functional change reported to MIIT.
  • Platform or billing file, where that role exists: provider identity checks, review and monitoring results, permission disclosures, takedown and complaint records, 60-day traceability data, and five-month billing records.
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Primary sources

References and citations

MIIT and CAC Notice on Further Regulating Preinstalled Mobile Smart Terminal Apps
miit.gov.cn3 citations
Referenced sections
  • Official 2022 notice defining basic-function software more narrowly and applying updated manufacturer controls from 1 January 2023.
  • Defines the limited basic-function categories, confirms that other preinstalled apps must be uninstallable, and requires controls against operating-system replacement and channel-installed apps from 1 January 2023.
  • Confirms manufacturer responsibility for safe, disclosed and uninstallable preinstalled apps and for controls against unauthorized software changes in distribution.
MIIT Interim Provisions on Preinstallation and Distribution of Mobile Smart Terminal Apps
miit.gov.cn3 citations
Referenced sections
  • Official text of 工信部信管〔2016〕407号, including scope definitions and manufacturer, distributor, billing, disclosure, consent, uninstallability, traceability and enforcement provisions effective 1 July 2017.
  • Articles 2 and 5-7 establish scope, notice and consent, disclosure, uninstallability, upgrade behavior, network-access consistency and change reporting; the provisions took effect on 1 July 2017.
  • Articles 5-10 distinguish billing, manufacturer and distribution-platform records and duties, including five-month billing retention and at least 60 days for platform traceability data.

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