Layla Zulfa
Core Mandates and Institutional Accountability
The new provisions apply to any entity providing multi-channel distribution services within the mainland territory of the People’s Republic of China. Under Article 30, "multi-channel distribution services" are defined broadly as activities including planning, production, distribution, marketing, promotion, and brokerage services provided for internet user public accounts. This definition effectively encompasses the vast majority of professional influencer management agencies and content incubators operating on platforms such as Douyin, Kuaishou, Weibo, and Bilibili.
A central pillar of the regulation is the requirement for formal business registration. Article 6 mandates that MCN agencies must register as legal business entities with a scope of operation specifically including "Internet information content multi-channel distribution services." For agencies already in operation, a 30-day grace period from the date of implementation is provided to update their business registrations. Furthermore, any MCN engaging in specialized fields—such as news reporting, cultural performances, online publishing, or radio and television production—must obtain the corresponding administrative licenses. The provisions strictly prohibit providing services that exceed the scope of an entity’s verified licenses.
To ensure transparency, Article 11 requires internet platforms to display the name of the managing MCN agency prominently on the profile pages of signed influencers. This "clear labeling" is intended to prevent agencies from operating behind a veil of anonymity, particularly when multiple accounts are used to push coordinated narratives or marketing campaigns. Agencies are also explicitly forbidden from "illegally renting or lending" their platform management accounts to third parties.
A Chronology of Digital Content Governance
The introduction of these provisions is the culmination of a decade-long regulatory evolution in China’s cyberspace. The timeline below illustrates the path toward the 2026 implementation:
- June 2017: The PRC Cybersecurity Law takes effect, establishing the foundational principle that "the state creates a peaceful, secure, open, and cooperative cyberspace."
- 2020–2021: The "Clear and Bright" (Qinglang) campaigns begin targeting "chaos" in fan circles, irrational celebrity worship, and illegal content production.
- September 2021: The CAC issues a notice on strengthening the management of MCN agencies, signaling that agencies would be held liable for the misconduct of the influencers they manage.
- 2022–2023: Draft versions of the Multi-Channel Distribution provisions are circulated for public comment, emphasizing the need for MCNs to verify the identities of their signed creators.
- 2024–2025: High-profile cases of tax evasion and "fake news" propagation by top-tier live-streamers lead to calls for more rigid institutional oversight.
- September 1, 2026: The finalized Provisions on the Management of Multi-Channel Distribution Services for Internet Information Content enter into force.
Supporting Data: The Scale of the MCN Industry
The necessity for such detailed regulation is underscored by the explosive growth of the Chinese MCN market. According to industry data from iMedia Research and various domestic securities firms, the number of MCN agencies in China grew from approximately 160 in 2015 to over 40,000 by 2023. The market size for MCN-related services exceeded 50 billion RMB (approximately $7 billion USD) in 2024, driven primarily by the live-streaming e-commerce boom.
Furthermore, statistics from the China Internet Network Information Center (CNNIC) indicate that as of early 2024, over 90% of "top-tier" influencers (those with over one million followers) are signed to MCN agencies. This concentration of digital influence means that a single agency can control the information flow to tens of millions of users. Regulators have expressed concern that without institutionalized checks, these agencies can easily manipulate public opinion, engage in unfair competition, or bypass content moderation protocols.
Prohibited Acts and Content Standards
Chapter 3 of the provisions outlines rigorous service specifications. MCNs are encouraged to produce content that aligns with "socialist core values" and promotes traditional Chinese culture. Conversely, Article 17 provides a detailed list of prohibited behaviors that have historically plagued the industry:
- Fabrication and Manipulation: Agencies are forbidden from synthesizing fake news, creating artificial trending topics, or "recycling old news" to mislead the public.
- Emotional Provocation: The regulations ban the incitement of regional discrimination or the stirring of "group antagonism" to generate engagement.
- Data Fraud: A major target of the law is the "water army" phenomenon. Article 17(5) prohibits the fabrication of followers, "likes," click-through rates, and sales figures through manual or automated means.
- Marketing Deception: MCNs must not create fake "personae" (character settings) or scripted scenarios that mislead consumers during e-commerce activities.
- Protection of Minors: Article 18 explicitly forbids MCNs from providing live-streaming distribution services to minors under the age of 16. For those aged 16 to 18, agencies must verify identities and obtain written consent from legal guardians.
Official Responses and Enforcement Mechanisms
The State Internet Information Office has emphasized that the management of MCNs is a "systemic project" requiring inter-departmental cooperation. In a press briefing following the announcement, a spokesperson for the CAC noted that the office would work closely with the Ministry of Public Security to crack down on MCNs involved in organized online crime, such as extortion under the guise of "public opinion monitoring."
The SAMR has also indicated that it will use these provisions to enhance its oversight of live-streaming e-commerce. "The era of MCNs operating in a regulatory gray zone is over," a representative stated. "By requiring agencies to sign formal entry agreements with platforms and verifying the identities of their creators, we are creating a traceable chain of responsibility for every product sold and every claim made online."
Enforcement will be handled through a tiered management system. Article 10 mandates that platforms categorize MCNs based on their compliance record, the number of signed accounts, and the total follower count. Agencies with poor credit scores or a history of violations will face "limited account functions," "suspension of profit-sharing," or "permanent banishment" from the platform.
Broader Impact and Industry Implications
The implementation of these provisions is expected to trigger a period of consolidation within the MCN industry. Smaller agencies that lack the legal and compliance infrastructure to meet the new standards may be forced to merge or exit the market. For larger agencies, the cost of compliance—including the requirement to hire dedicated content audit teams as mandated by Article 6—will rise significantly.
From a broader perspective, the regulations signify a shift in accountability. Previously, platforms were the primary gatekeepers, and individual influencers were the primary targets of punishment. The new rules place the MCN agency at the center of the liability web. If a signed influencer violates the law, the MCN can be held responsible for "failing to provide adequate guidance and oversight."
Legal experts suggest that this "institutional liability" model is designed to force the industry to self-regulate. By making the MCN’s business license dependent on the behavior of its influencers, the state is effectively outsourcing a portion of its content monitoring to the agencies themselves.
As the September 2026 deadline approaches, the digital content landscape in China is poised for a transformation. The focus will move away from raw traffic growth at any cost toward a model of "compliance-first" content production. While some critics argue that the strict rules could stifle creativity, proponents maintain that the provisions are essential for protecting consumers from fraud and ensuring that the digital economy remains a stable component of the national social fabric. In the long term, these measures are intended to professionalize the "influencer economy," turning it from a chaotic frontier into a regulated professional industry.
Nana
Ammar Sabilarrohman
