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2023 marked a year of explosive growth for online micro-dramas in China. Featuring "short duration, fast pace and gripping plots", online micro-dramas have quickly caught audiences' attention, and the topical popularity of hit micro-dramas once surpassed that of a large number of horizontal-screen long-form dramas. According to data released by the National Radio and Television Administration (NRTA), the number of online micro-dramas completing record-filing for official launch in 2022 reached 336, marking a 214% year-on-year increase, and this figure further rose to 584 in 2023. The explosive growth of online micro-dramas has rapidly attracted increasing input of human resources, technologies and investment, and a unique industrial chain has taken shape. However, in the initial development stage of online micro-dramas, the sector was once in a phase of "disorderly and unregulated growth" due to the lack of regulatory policies. To obtain traffic, some production and releasing entities of micro-dramas tended to incorporate gory, violent, pornographic and other inappropriate elements into their works. Various problems have gradually emerged along with the explosive growth of online micro-dramas. To ensure the long-term and stable development of online micro-dramas, China has successively rolled out a series of regulatory policies, and established the Special Committee on Micro-Dramas of the China Television Artists Association (hereinafter referred to as the "Micro-Drama Special Committee") on May 18, 2024, which further demonstrates the importance China attaches to the micro-drama industry. With the establishment of the Micro-Drama Special Committee and the formulation and improvement of various regulatory policies, the online micro-drama sector will definitely break away from the state of "disorderly and unregulated growth" in a short period of time, with its content developing towards high quality and its promotion and distribution methods becoming increasingly standardized. On this basis, the commercial operation model of online micro-dramas will surely mature.

I. Official Definition of Micro-Short Dramas

On December 8, 2020, the National Radio and Television Administration promulgated the *Circular on Issues Concerning the Content Review of Short Web Dramas in Online Film and Television Dramas*, which officially defines short web dramas as online film and television dramas with a duration of less than 10 minutes per episode. It is the fourth officially recognized form of online film and television works following online film and television dramas, online films and online animations.

On November 14, 2022, the National Radio and Television Administration of China issued the *Notice on Relevant Work Concerning Further Strengthening the Administration of Online Micro-Short Dramas and Implementing the Creation Promotion Plan*, which stipulates the content standards for micro-short dramas as follows: each episode lasts from dozens of seconds to approximately 15 minutes, with relatively explicit themes and main plotlines, as well as relatively coherent and complete storylines.

At the end of 2022, the National Radio and Television Administration updated the provisions on the duration of micro-short dramas in the *Online Micro-short Drama Section* of the Information Filing System for Key Online Film and Television Programs, stipulating that the filing duration of a single episode shall be no more than 20 minutes.

II. Development Trajectory of Increasingly Stringent Policy Regulation on Micro-short Dramas

(I) Supervision over Short Drama Content Is Becoming Increasingly Stringent

On November 2, 2020, the General Office of the National Radio and Television Administration of China issued the *Notice on Issues Concerning Content Review of Short Online Mini-Dramas in Online Film and Television Dramas*. For the first time, the category of "short online mini-dramas" was added to the filing of key online film and television dramas, promoting the gradual standardization of short online mini-dramas.

2. On December 15, 2021, the China Netcasting Services Association issued the industry norm *Detailed Rules for Content Review Standards of Online Short Videos (2021)*, which sets out the detailed standards for online short video review and specifies 21 categories of prohibited content, including: content detrimental to China's national image or promoting national secession (such as "Taiwan independence"); content hyping social hot issues, intensifying social contradictions and undermining social stability; content distorting history and historical figures; content glorifying villainous and negative figures (for example, some novels glorify drug traffickers, and such intellectual property (IP) cannot be adapted into compliant short videos); content containing vulgar language and displaying indecent behavior; content that uses veiled, obscene language to induce sexual associations, etc.

3. On November 14, 2022, the General Office of the National Radio and Television Administration of China issued the *Notice on Relevant Work Concerning Further Strengthening the Administration of Online Short Dramas and Implementing the Creation Improvement Plan*, which explicitly stipulates that online short dramas, online series and online films shall be administered in accordance with the same standards and the same yardstick. It proposes to launch a special rectification campaign targeting online short dramas hosted on "Mini Programs". Non-compliant short dramas shall be ordered to make rectification or be forcibly taken offline. For "Mini Programs" disseminating non-compliant online short dramas and their operating entities, penalties such as link removal, being taken offline, delisting, cancellation of record-filing, suspension of access services, revocation of relevant permits and joint disciplinary actions shall be imposed in light of the severity of the circumstances. In addition, the Notice advocates innovation, adheres to the content-first principle, scales up support for high-quality works on the basis of strengthening content review, and guides the creation direction of short dramas toward high quality and innovation.

(II) The pre-launch filing of micro-short dramas is becoming increasingly standardized.

On April 29, 2022, the National Radio and Television Administration issued the *Notice of the General Office of the National Radio and Television Administration on Relevant Matters Concerning the Administration of Distribution Licensing Services for Domestically Produced Online Drama and Film Productions* (Guangdian Ban Fa [2022] No. 128). The Notice stipulates that competent radio and television authorities shall implement focused supervision over key domestically produced online drama and film productions. Online dramas, online micro-short dramas, online films and online animations that meet one or more of the following conditions shall obtain the *Online Drama and Film Distribution License* issued by the competent radio and television authorities in accordance with the law:

(1) Where the investment amount is relatively large, the specific amount shall be determined by the competent radio and television department under the State Council in accordance with the online audio-visual industry.

shall be adjusted and notified in a timely manner in light of the actual work conditions of industry development and administration;

(2) Those mainly promoted for investment solicitation by online audio-visual program service providers;

(3) Content recommended for broadcast on the first screen of the homepage of a website (client), in special sections, or in special zones and columns;

(4) Giving priority to members in the provision of viewing services, or providing viewing services on a paid basis;

(5) Where an entity engaged in the production and distribution of online dramas and films voluntarily files an application to declare the relevant work as a key online drama or film.

This Notification stipulates for the first time that online micro-short dramas are subject to the same regulatory standards as online dramas, online films and online animations, and shall obtain the *Distribution License for Online Dramas and Films* when meeting the relevant eligibility requirements. Online micro-short dramas have hence entered an era of strict supervision, yet the aforesaid Notification does not define the criteria for "relatively large investment amount".

2. On November 14, 2022, the General Office of the National Radio and Television Administration issued the *Notice on Relevant Work Concerning Further Strengthening the Administration of Online Micro-Short Dramas and Implementing the Creation Enhancement Plan*, which further clarifies that all entities and links involved in the creation and dissemination of online micro-short dramas shall be placed under integrated management in compliance with the principle of consistent administration of online audio-visual services.

Specifically:

All entities providing online short drama services, including those operating short drama-themed Mini Programs, shall obtain the *License for Audio-Visual Program Transmission over Information Networks*, or be placed under the standardized administration of radio and television administrative authorities in accordance with relevant regulations. All online short dramas shall pass the content review conducted by radio and television administrative authorities, and obtain the *Online Drama and Film Distribution License*, or complete the registration of online audio-visual programs pursuant to relevant provisions on the administration of online dramas and films. When licensed works are launched for broadcast, the unified logo and license number shall be displayed in a prominent position at the opening of the program, to be subject to public supervision and full-cycle supervision throughout the entire online operation period. Online short dramas that have not obtained the distribution license shall be gradually removed from the first screen of the homepage.

3. On May 30, 2023, the Department of Network Audiovisual Program Management of the National Radio and Television Administration of China issued the *Administrative Notice on Distribution Licensing and Broadcasting of Online Drama and Film Programs*. The Notice stipulates that as of June 1, 2023, newly launched online mini-dramas shall be works that have been declared through the Information Filing System for Key Online Film and Television Programs, passed content review by radio and television administrative authorities at or above the provincial level, and obtained either the *Online Drama and Film Distribution License* or the online broadcasting filing number. It further clarifies that works holding the *Online Drama and Film Distribution License* may be released on multiple online platforms, while works that only obtain the online broadcasting filing number may only be broadcast after registration on a single online platform.

The promulgation of the aforesaid provisions imposes restrictions on online short drama broadcasting platforms adopting different filing methods, which directly affects the viewership and traffic of online short drama works. As traffic has a direct impact on the direct operating revenue and advertising proceeds of online short dramas, we hold that producers of online short dramas will be more inclined to obtain the *Online Series and Film Distribution License*.

(The image shows the login page of the "Key Online Film and Television Drama Information Filing System", URL: http://211.146.10.138:8080/YSJBA/)

4. On June 1, 2024, new regulations concerning the filing of micro-short dramas officially came into force. The core provision of the said new regulations reads: "As of June 1, 2024, micro-short dramas that have not been reviewed and filed shall not be disseminated online". Micro-short dramas are classified on the basis of investment amount, and different levels of micro-short dramas correspond to different filing numbers, with details specified as follows:

(1) "Key Micro-series" (referring to micro-series that meet any of the following conditions: covering special subject matters, with a total investment of RMB 1,000,000 or above, promoted as key investment attraction projects by long and short video platforms, broadcast with recommendation on the first screen of the homepage of various terminals, or voluntarily declared as key micro-series) shall be subject to unified record-filing, public announcement and administration of the National Radio and Television Administration of China. Prior to going online, the unique license number of the program shall be marked at the opening of the program in the format: (X) Wang Wei Ju Shen Zi (Year) No. ***, and its specific presentation is shown in the figure:

(The image is a screenshot of the opening title of a duly filed micro-short drama randomly selected by the author.)

(2) "Ordinary micro-short dramas" (referring to programs with a total investment amount ranging from RMB 300,000 (inclusive) to RMB 1,000,000 and not categorized as key recommended programs) shall be filed via the Online Audio-Visual Program Filing System of the National Radio and Television Administration (NRTA). The provincial-level radio and television administration shall be responsible for planning filing review and completed production examination. Prior to going online, the unique registration and filing number of the program shall be marked on the opening title of the program in the format of: (X) Wang Wei Ju Bei Zi (Year) No. ***. The author attempted to find already launched ordinary micro-short dramas on micro-short drama streaming platforms, but no such filing record was found after searching through multiple micro-short dramas.

(The image shows the login page of the Online Audio-Visual Program Filing System, website URL: http://117.134.1.55:9034/)

(3) "Other micro short dramas" (referring to works with a total investment of less than RMB 300,000 and not listed as key recommended programs) shall have their content management duties performed by online audio-visual platforms that broadcast, direct traffic to or push such works. The aforesaid platforms shall be responsible for content review and approval as well as copyright verification. Prior to the launch and broadcast of such dramas, the program filing number shall be displayed in a conspicuous position in the following format: (Abbreviation of the Broadcasting Platform) Online Micro Short Drama Filing No. (Year) ***.

The promulgation of the aforementioned new regulations indicates that short dramas are now regulated as formal film and television productions, but it also poses new challenges to micro-short drama practitioners. Strict supervision over short drama content means that short drama producers or investors shall make more rational decisions when selecting works for investment and production, and may not invest in borderline works as they did in the past. Otherwise, the removal of a work from online platforms may result in heavy losses for investors. The pre-launch record-filing review for short dramas will also extend the launch cycle of short dramas, increasing communication and time costs. If producers blindly follow trends to produce works based on online hot topics, the relevant topics may have lost popularity by the time the work is launched, leading to investment losses. Therefore, high-quality content and lawful and compliant record-filing methods have become the key factors for the explosive popularity of micro-short dramas under the current regulatory environment. Those who blindly produce works that merely pander to hot topics, or contain vulgar and violent content may eventually be expelled from the short drama market.

The above constitutes the author's interpretation of the current regulatory policies. Subsequently, the author will analyze the risks and opportunities faced by parties involved in each link of the short online drama industry chain and put forward targeted recommendations. Please stay tuned.