--- title: "Do preinstalled mobile apps have special China requirements?" canonical_url: "https://www.sorena.io/artifacts/apac/china-telecom-wireless-regulation/faq/do-preinstalled-mobile-apps-have-special-china-requirements" source_url: "https://www.sorena.io/artifacts/apac/china-telecom-wireless-regulation/faq/do-preinstalled-mobile-apps-have-special-china-requirements" author: "Sorena AI" description: "Yes. Covered mobile smart terminals have China-specific duties for app disclosure, consent, uninstallability, upgrade behavior, distribution controls and network-access consistency." published_at: "2026-07-05" updated_at: "2026-07-24" keywords: - "China telecom" - "Network access permit" - "Radio management" - "Wireless equipment" - "Mobile terminal apps" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # Do preinstalled mobile apps have special China requirements? Yes. Covered mobile smart terminals have China-specific duties for app disclosure, consent, uninstallability, upgrade behavior, distribution controls and network-access consistency. *Question* *China* ## Do preinstalled mobile apps have special China requirements? Direct answer Yes. A manufacturer of a covered mobile smart terminal 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. Yes, if the product is a mobile smart terminal: 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. ## Definitions ### Mobile smart terminal A mobile smart terminal is a mobile communications terminal that connects to a public mobile communications network, has an operating system, and allows the user to install and uninstall mobile apps. The definition covers the terminal products subject to MIIT's preinstallation rules; a connected product without all three features is not brought into this rule by connectivity alone. **Why it matters here:** The manufacturer duties on this page apply when the product meets this terminal definition. App-distribution platforms, app providers, and billing providers have separate duties based on the role they perform. Sources: - [MIIT Interim Provisions on Preinstallation and Distribution of Mobile Smart Terminal Apps](https://www.miit.gov.cn/jgsj/xgj/gzdt/art/2020/art_bdc41fa5f1dd4a7d9f99b0dc8c483e52.html?ref=sorena.io) ### Basic-function software Basic-function software is preinstalled software within one of four limited categories: system settings and file management; multimedia capture; calls, text messages, contacts, and browser; or an app-download channel. No more than one preinstalled app for the same basic function may be set as non-uninstallable. **Why it matters here:** This classification controls the uninstallability exception. A manufacturer should classify each preinstalled app by its actual function and retain the reason for treating any app as non-uninstallable. Sources: - [MIIT and CAC Notice on Further Regulating Preinstalled Mobile Smart Terminal Apps](https://www.miit.gov.cn/jgsj/xgj/sbgl/art/2022/art_faae1abfbd144f31bd543bd551950a8e.html?ref=sorena.io) ## 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, basic-function software is limited to system settings and file management; multimedia capture; calls, text messages, contacts and browser; and the app store. At most one preinstalled app 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 preinstalled app from being forced back during an operating-system upgrade and must take measures against operating-system replacement or unauthorized app installation in distribution channels. Sources for this answer: - [MIIT Interim Provisions on Preinstallation and Distribution of Mobile Smart Terminal Apps](https://www.miit.gov.cn/jgsj/xgj/gzdt/art/2020/art_bdc41fa5f1dd4a7d9f99b0dc8c483e52.html?ref=sorena.io) - 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. - [MIIT and CAC Notice on Further Regulating Preinstalled Mobile Smart Terminal Apps](https://www.miit.gov.cn/jgsj/xgj/sbgl/art/2022/art_faae1abfbd144f31bd543bd551950a8e.html?ref=sorena.io) - 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. ## Separate manufacturer and platform duties Do not assign every obligation to the device maker. An app-distribution platform must register provider, operator and developer identity and contact details; review and test apps; monitor and remove unlawful or malicious apps; disclose requested permissions and their purposes; and operate complaint handling. It must retain the distributed app and version, release time, function, purpose, MD5 checksum 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. Sources for this answer: - [MIIT Interim Provisions on Preinstallation and Distribution of Mobile Smart Terminal Apps](https://www.miit.gov.cn/jgsj/xgj/gzdt/art/2020/art_bdc41fa5f1dd4a7d9f99b0dc8c483e52.html?ref=sorena.io) - 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. - [MIIT and CAC Notice on Further Regulating Preinstalled Mobile Smart Terminal Apps](https://www.miit.gov.cn/jgsj/xgj/sbgl/art/2022/art_faae1abfbd144f31bd543bd551950a8e.html?ref=sorena.io) - Confirms manufacturer responsibility for safe, disclosed and uninstallable preinstalled apps and for controls against unauthorized software changes in distribution. ## Primary sources - [MIIT Interim Provisions on Preinstallation and Distribution of Mobile Smart Terminal Apps](https://www.miit.gov.cn/jgsj/xgj/gzdt/art/2020/art_bdc41fa5f1dd4a7d9f99b0dc8c483e52.html?ref=sorena.io) - 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. - [MIIT and CAC Notice on Further Regulating Preinstalled Mobile Smart Terminal Apps](https://www.miit.gov.cn/jgsj/xgj/sbgl/art/2022/art_faae1abfbd144f31bd543bd551950a8e.html?ref=sorena.io) - Official 2022 notice defining basic-function software more narrowly and applying updated manufacturer controls from 1 January 2023. ## Topic Guides - [2400MHz, 5100MHz and 5800MHz radio equipment rules](/artifacts/apac/china-telecom-wireless-regulation/radio-equipment-2400-5100-5800-mhz.md): Band-specific China radio management requirements, implementation timing, and equipment evidence for products using these bands. - [China network access vs radio management](/artifacts/apac/china-telecom-wireless-regulation/china-network-access-vs-radio-approval.md): Crosswalk separating telecom network access licensing from radio transmitting equipment management for connected products. - [China telecom and wireless deadlines and compliance calendar](/artifacts/apac/china-telecom-wireless-regulation/deadlines-and-compliance-calendar.md): China telecom and wireless commencement dates, permit lead times, renewals, transitions, and change-triggered filings. - [China telecom and wireless equipment requirements](/artifacts/apac/china-telecom-wireless-regulation/requirements.md): China network access, radio management, micro-power equipment, and mobile terminal app requirements for connected-device launch teams. - [China Telecom and Wireless FAQ](/artifacts/apac/china-telecom-wireless-regulation/faq.md): China connected-device FAQ covering network access permits, radio model approval, station licensing, 2400/5100/5800MHz rules and preinstalled mobile apps. - [China telecom and wireless launch checklist](/artifacts/apac/china-telecom-wireless-regulation/checklist.md): Release-gate checklist for China network access permits, radio band rules, micro-power equipment and preinstalled mobile apps. - [China telecom and wireless penalties and enforcement exposure](/artifacts/apac/china-telecom-wireless-regulation/penalties-and-fines.md): China penalties for unlicensed telecom equipment, radio model approval, station licensing, interference, and mobile app violations. - [China Telecom Equipment Network Access Permit Workflow](/artifacts/apac/china-telecom-wireless-regulation/telecom-equipment-network-access-license.md): Decide whether equipment needs a China network access permit, then prepare the applicant, test, application, mark, renewal and change evidence. - [Connected device China launch workflow](/artifacts/apac/china-telecom-wireless-regulation/connected-device-china-launch-workflow.md): Decide which China network-access, radio, micro-power and mobile-terminal app requirements apply to a connected-device model, then control the evidence through release. - [Does my connected device need a China network access permit?](/artifacts/apac/china-telecom-wireless-regulation/faq/does-my-connected-device-need-china-network-access-permit.md): Not every connected device needs a China network access permit. Check public-network connection, the current MIIT equipment directory, and the 2023 licensing reforms. - [Is radio management separate from network access in China?](/artifacts/apac/china-telecom-wireless-regulation/faq/is-radio-management-separate-from-network-access-in-china.md): Yes. China network access and radio management use different scope tests and approvals. A product can need both, one, or neither. - [Micro-power short-range radio equipment rules](/artifacts/apac/china-telecom-wireless-regulation/micro-power-short-range-radio-equipment.md): How to use the micro-power short-range radio equipment catalogue and technical requirements in China launch triage. - [Mobile terminal preinstalled app requirements](/artifacts/apac/china-telecom-wireless-regulation/mobile-terminal-preinstalled-apps.md): China mobile smart terminal preinstallation and distribution duties for device makers and app distribution workflows. - [Network access permit application evidence template](/artifacts/apac/china-telecom-wireless-regulation/network-access-permit-application-evidence-template.md): Model-level evidence index for a China telecom equipment network-access permit, from catalogue decision and applicant records through trial evidence, filing, approval and renewal. - [Preinstalled app user rights and removal checks](/artifacts/apac/china-telecom-wireless-regulation/preinstalled-app-user-rights-and-removal.md): Practical checks for mobile terminal preinstalled app distribution, user-facing controls, and cited evidence. - [What changed for 2400MHz, 5100MHz and 5800MHz equipment?](/artifacts/apac/china-telecom-wireless-regulation/faq/what-changed-for-2400-5100-5800-mhz-equipment.md): MIIT's 2021 notice revised band uses, radio technical limits, interference controls, model approval and station licensing for 2400MHz, 5100MHz and 5800MHz equipment. - [What evidence is needed for a network access permit?](/artifacts/apac/china-telecom-wireless-regulation/faq/what-evidence-is-needed-for-a-network-access-permit.md): China network-access permit evidence: Chinese application forms, applicant and manufacturer records, quality evidence, product description, test or certification records, and any required network-trial file. *Operationalize the requirement* *Placement: Before cited sources* ## Prepare the China connected-device launch file Connect the answer to the exact product facts, applicable cited source, accountable owner and retained evidence. - [Map cited sources to evidence](/solutions/research-copilot.md): Research Copilot connects the citation, decision, owner, retained evidence, and change history. - [Review the China route](/contact.md): Review unresolved equipment classification, approval or product-change questions before release. --- [Privacy Policy](https://www.sorena.io/privacy.md) | [Terms of Use](https://www.sorena.io/terms-of-use.md) | [DMCA](https://www.sorena.io/dmca.md) | [About Us](https://www.sorena.io/about-us.md) (c) 2026 Sorena AB (559573-7338). 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