Effective April! 8 Departments Jointly Issue Document! Major New Rules for Minor Protection — Two Types of Platforms Will Be 'Key Targets'!

In recent years, minor online protection has been the “sword of Damocles” hanging over all internet companies and game developers. (Especially given that the actual amounts involved in minor recharge are often not very high.)

Whether it’s implementing anti-addiction systems, handling minor refund disputes, or content review involving minors, one misstep can lead to a serious compliance crisis.

Previously, many platforms faced a common question when dealing with special obligations under the “Regulations on the Protection of Minors Online” regarding “huge numbers of minor users” or “significant influence”:

“How many is ‘huge’? My game/APP has only a few hundred thousand DAU — is that ‘significant influence’?”

Now, the standard is finally here.

On February 11, 2026, eight core government departments — including the Cyberspace Administration of China, the National Press and Publication Administration, the Ministry of Education, and the Ministry of Public Security — jointly issued the “Measures for Identifying Providers of Online Platform Services with a Huge Number of Minor Users and with Significant Influence on Minors” (hereinafter referred to as the “Measures”), effective April 1, 2026.

This new regulation, for the first time, uses clear data indicators and comprehensive dimensions to define which platforms will become “key supervision targets” for minor protection.

Below, we break down the core points most relevant to online platforms (especially games, short videos, and social applications):

1. Exactly How Many Is “Huge”?

For internet and game companies, the thing they fear most is vague concepts. (Especially because it’s hard for legal teams to communicate with project teams.)

This time, the most critical breakthrough of the Measures is setting two hard quantitative standards (Article 6) for what counts as a “huge number of minor users.”

If either condition is met, the legal team can directly and confidently demand that the project conduct a self-audit:

Exclusive Platforms

Products specifically targeting minors (e.g., children’s programming apps, children’s games, primary/secondary education products) with 10 million+ registered users or 1 million+ monthly active users (MAU) who are minors.

Comprehensive Platforms

Products whose audience is not limited to minors (e.g., mainstream large-scale online games, short video platforms, social apps), with 10 million+ registered minor users or 1 million+ monthly active minor users.

Note that the regulation uses the term: 【Platform】

In the past, some developers (especially mid-tier ones) might think their games are all-age, or that they have enough games across enough genres — with few all-age games and not many minor users per game — to evade the strict supervision targeting minors. They weren’t as strict as the top-tier companies.

But now, it’s all about the “total pie.” If the total minor MAU across all game products exceeds 1 million, they will bear the same “giant-level” minor protection obligations (e.g., establishing external independent supervisory bodies, conducting regular compliance audits).

To avoid compliance risks, developers must have extremely accurate real-name verification and user profiling to count the number of minor users across all products.

They need to carefully consider whether to drive away these users or continue handling them compliantly.

2. But It’s Not Just About Big Numbers

If my minor MAU is only 500K, am I in the clear?

— A producer’s inner thoughts

(Objection) Not quite.

Article 7 of the Measures clarifies the criteria for determining “significant influence on minors.”

Even if the absolute number of minor users hasn’t hit the red line above, the platform may still be designated under the following circumstances:

Any major company qualifies

If the platform is a well-known major company, has a large total number of downloads and users, or has significant product sales volume or transaction volume.

High Data Stickiness

If indicators like minor login frequency, usage duration, usage preferences, and spending amounts are high.

For example, certain anime-style gacha games — even if the total number of minor users is small, their average online time is extremely long (maxing out the daily playtime limit) and their spending is very high (hitting the monthly recharge cap).

High Content Concentration

If the platform hosts a large amount of information content involving or targeting minors.

(E.g., a long-form video platform primarily featuring anime content.)

Vertical Domain Leader

If the platform is a representative platform in a vertical domain involving minors.

Prior Violations

If the platform has had numerous violations involving minors in the past 3 years, with significant negative impact.

In my view, this clause gives regulatory authorities greater flexible discretion. While Article 6 provides numbers, this one blurs things again. How much is “significant”? How “high” is “high”? How “numerous” is “numerous”? No precise figures. But the core message is: don’t try to exploit the loophole by staying just under the 1 million MAU threshold. If your product ecosystem has a substantial real impact on children (especially negative impact), you’ll be on the list.

3. Proactive Reporting and Retroactive Investigation

Previously, designations were often “top-down” notifications. But this time, the Measures adopt a dual-track system of “voluntary application + official retroactive investigation.”

Article 9 requires platforms to conduct self-assessment.

If a developer finds it meets the criteria, it must proactively apply for designation and submit a self-assessment report.

What if someone thinks “we’ll deal with it when the regulators come knocking”? (AKA: “deal with it when inspected”)

Article 10 clarifies that the Designation Work Advisory Committee will propose a recommended list based on actual circumstances (i.e., monitoring which products suddenly blow up, or hearing about them from their own children or friends).

Once officially notified, the platform must submit a self-assessment report within 20 working days.

More severely, if materials submitted contain false information or conceal important facts (e.g., deliberately using technical means to hide minor activity data, temporarily deleting minor users, or magically turning all minors into adults), the platform will face legal penalties from the cyberspace and other authorities!

Additionally, the designation process is generally conducted every 3 years.

But!

If your game suddenly blows up (congratulations!) or significantly increases its influence on minors (e.g., by collaborating with a minor-oriented IP or becoming a meme spreading among minor users), the authorities can “initiate at any time.”

4. Both Entry and Exit — The List Isn’t “Lifetime”

Once on the list, a platform faces “strict supervision.” Does that mean it can never transition out?

Not necessarily.

Article 16 provides a humane “opt-out mechanism”:

If a designated platform, by adjusting its product positioning, strengthening real-name blocking, cleaning up relevant content, etc., consistently fails to meet the designation criteria for 6 consecutive months, it can proactively submit a change application and, upon review, be removed from the list.

Therefore, mid-tier developers may consider:

If they don’t want to bear the extremely high compliance costs and joint liability of a “special platform,” they can proactively reduce the proportion of minor users through technical means (e.g., completely banning minor registration, significantly restricting minor services, actively striving to become the “old man’s product” in the eyes of minor users). This way, they can “take off the hat” and avoid substantial compliance costs.

But looking at it this way, minor users will have fewer and fewer game products to choose from in the future.

5. How to Respond?

The new regulation takes effect on April 1, leaving little time for enterprises to self-audit and adjust. How should enterprises respond?

In my view, the following steps should be taken:

1. Know Your Numbers (Create a Ledger)

Legal teams should immediately hold meetings with operations, pull backend data, especially real-name authentication-based minor “registered users” and “MAU.”

For unverified accounts or accounts suspected of belonging to minors (e.g., a parent’s account used by a child — the “face-swapping” situation), improve detection algorithms, perhaps adding AI-based judgments, to ensure an accurate understanding of the scale of minor users.

2. Benchmark Against Standards (Self-Audit)

Legal and compliance departments (if any) should take the lead as early as possible. Use the quantitative and comprehensive indicators of the Measures (search online for your company’s minor-related reputation) to simulate scoring.

If you’re near the red line, prepare a compliance response plan or self-assessment report in advance. Don’t wait for an official notification before reacting.

3. Fill Gaps (Review)

If the platform meets the “significant influence” criteria (e.g., high minor spending amounts), focus on reviewing recent operational activities, gacha probabilities, anti-addiction refund complaint rates, etc.

Pay special attention to evaluations on platforms like XiaoHongShu and DouYin.

Minimize the risk of violations involving minors to avoid being forcibly added to the list due to “significant negative impact.”

4. Calculate the Big Picture (Do Subtraction)

Do you really want these minor users?

Are they worth the additional regulatory burden?

Every developer — especially small and medium ones — should think this through.

6. Finally

From the enactment of the “Regulations on the Protection of Minors Online” to the comprehensive rollout of anti-addiction systems, to today’s release of the “Measures,” China’s legal framework for online protection of minors is becoming increasingly tight and operational.

“With great power comes great responsibility.”

The essence of the Measures is to require top-tier products — which capture a significant amount of minors’ attention and time — to bear corresponding social responsibility.

For internet and game enterprises operating in compliance, clear rule boundaries are often more instructive than vague policies. Once the red line is clear, enterprises can better balance commercial development with social responsibility.

Protecting minors means protecting the future of the industry. I believe that with more precise and scientific regulation, China’s online ecosystem will become healthier, truly creating a clear online space for minors.