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Content Interpretation

The China Film Administration issued the *Notice on Promoting the Orderly Development of Virtual Reality Films* on March 18, 2025. It aims to advance the in-depth integration of virtual reality (VR) technology and the film industry, standardize the administration of emerging business forms, and contribute to attaining the goal of building China into a "film power". For the first time, the Notice explicitly defines the connotation of virtual reality films, namely, a new form of film produced via comprehensive application of virtual reality (including augmented reality and mixed reality) technologies, viewed through head-mounted display devices, and publicly screened in cinemas or other fixed venues complying with safety standards, whose core features are technology integration, immersive experience and standardized screening scenarios.

At the content management level, the Notice requires that production entities (legal persons or unincorporated organizations) shall complete the filing and review procedures. The script synopsis shall be filed with the China Film Administration, which shall issue a filing certificate accordingly, and the completed film may only be publicly screened after obtaining the *Film Public Screening Permit*, so as to ensure the ideological, artistic and ornamental quality of the content. With respect to screening site management, existing cinemas that screen VR films shall file for the record with the local competent authorities. Other permanent buildings conforming to safety standards (such as shopping malls, cultural and museum venues) shall apply for the *Film Screening Business Permit* and connect to the National Film Ticketing Management System to realize standardized supervision.

The development of the technical standard system serves as a key starting point of relevant policies. Film production, distribution and exhibition entities shall comply with the State provisions in aspects including content production, terminal equipment, playback software and venue conditions, so as to ensure stability, smoothness and security. At present, the public consultation for the *General Technical Specifications for Virtual Reality Films* has been completed. In the future, industry standards covering five dimensions, namely content production, equipment, rendering, playback software and venues, will be established. The policy also clarifies the industrial support orientation, allowing VR films equal access to existing support policies such as those for high-quality film creation and cinema subsidies, encouraging social entities to conduct innovation in fields including technology research and development, distribution revenue sharing and copyright protection, and empowering the development of VR technology by leveraging the mature production system, key protection mechanism and talent reserve of the film industry.

Notably, the policy focuses on "scaling up incremental business", and only applies to VR works that conform to China's film standards (e.g. content for theatrical screening), without interfering with existing business formats such as VR experience exhibitions in cultural and tourism scenic spots and commercial complexes. By standardizing review procedures, strengthening technical standards and facilitating the circulation of industrial resources, this policy has not only established a sustainable development framework for VR films, but also provided institutional guarantee for the expansion of new forms and the unleashing of new growth drivers of China's film industry.

2. Original Text of the Policy

Circular of the China Film Administration on Promoting the Sound and Orderly Development of Virtual Reality (VR) Films

Guoyingfa [2025] No. 2

To the competent film authorities of all provinces, autonomous regions and municipalities directly under the Central Government, and all relevant film entities:

Film is the product of the integration of culture, arts and scientific and technological innovation. In recent years, virtual reality has become an important frontier direction for the development of high and new technologies, providing brand-new audio-visual experiences for films. For the purposes of encouraging trials of new technologies, exploring new business forms, and supporting the integrated innovation of the film industry and virtual reality technology, in accordance with the *Film Industry Promotion Law of the People's Republic of China* and relevant laws and regulations, the Notice on Matters Relating to Promoting the Orderly Development of Virtual Reality Films is hereby issued as follows.

I. For the purpose of this Notice, the term "virtual reality film" refers to a new form of film produced by applying virtual reality (including augmented reality and mixed reality) related technologies, viewed through virtual reality terminals such as head-mounted display devices, and intended for public screening at fixed screening venues such as cinemas.

II. Legal persons and unincorporated organizations that produce virtual reality (VR) films shall comply with the relevant requirements of the *Film Industry Promotion Law of the People's Republic of China* and the *Provisions on the Administration of Film Script (Outline) Filing and Films*. Legal persons and unincorporated organizations intending to produce VR films shall submit film script outlines to the China Film Administration to complete the filing (examination) procedures. The China Film Administration shall announce applications that meet relevant provisions and issue corresponding filing certification documents. Legal persons and unincorporated organizations shall submit their completed VR films to the China Film Administration for examination, and obtain the Film Public Screening Permit in accordance with the law.

III. We support the exploration and utilization of space inside cinemas or other permanent buildings that comply with relevant national safety standards for the screening of virtual reality (VR) films. Where VR films are screened inside cinemas, film screening entities may complete the record-filing formalities with the competent film administrative departments that approved their establishment. Where VR films are screened in other buildings, relevant entities may apply for the *Film Screening Business Permit* in accordance with relevant provisions. Screening venues that already hold or have applied for the *Film Screening Business Permit* shall be connected to the National Comprehensive Film Ticketing Information Management System.

IV. Entities engaged in the production, distribution and exhibition of virtual reality (VR) films shall, in terms of content production, virtual reality terminals such as head-mounted display devices, playback software and venues, comply with the technical standards prescribed by the State and have sound stability, fluency, security and compatibility.

V. All relevant entities in the film industry and social forces are encouraged to actively explore areas including the research and development of virtual reality (VR) film technologies, creation and production, distribution and screening, etc. Enterprises in the VR film industrial chain shall be supported to continuously improve their technical standards and creative capabilities, and integrated innovation in aspects including VR film publicity and distribution, settlement and revenue sharing, and transmission supervision shall be advocated.

Section 6. The China Film Administration shall provide support and guarantee for the development of virtual reality (VR) films. Competent film administrative departments at the provincial level shall adapt measures to local conditions and actively promote the development of virtual reality films.

VII. The import of virtual reality films shall be implemented in accordance with the relevant provisions of the *Regulations on the Administration of Films*.

VIII. This Notice shall come into force as of the date of its promulgation.

China Film Administration

March 18, 2025