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Interpretation of China's Regulations and Policies on Micro-dramas

I. Content Regulation on Micro-Short Dramas Is Tightening

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

2. On December 15, 2021, the China Network Audio-Visual Program Service Association issued *Detailed Rules for Content Review Standards of Online Short Videos (2021)* as an industry regulatory norm. The document lays down detailed review standards for online short videos and specifies 21 categories of prohibited content, including: content damaging China's national image; content involving national secession (e.g. "Taiwan independence"); content hyping social hotspots, intensifying social conflicts and undermining social stability; content distorting history and historical figures; content glorifying villainous and negative figures (for instance, some novels glorify drug traffickers, and such intellectual properties (IPs) may not be adapted into compliant short videos); content containing vulgar language and displaying indecent behaviors; content using implicit and vulgar language to induce sexual associations, etc.

3. On November 14, 2022, the General Office of the National Radio and Television Administration issued the *Notice on Work Concerning Further Strengthening the Administration of Online Micro Short Dramas and Implementing the Creation Enhancement Plan*, which explicitly stipulates that online micro short dramas shall be administered in accordance with the same standards and same criteria as online series and online films. It proposes to launch special rectification targeting "mini-program" type online micro short dramas. Illegal micro short dramas shall be ordered to make rectification or be compulsorily removed from platforms; "mini-programs" that disseminate illegal online micro short dramas and their operating entities shall, in light of the seriousness of the circumstances, be imposed with penalty measures including link blocking, offline removal, delisting, cancellation of record-filing, suspension of access services, revocation of relevant permits and joint disciplinary action. In addition, the Notice encourages innovation, adheres to the content-oriented principle, and on the basis of strengthening content review, scales up support for high-quality works, to guide the creation of micro short dramas towards the direction of high quality and innovation.

II. The administrative filing of online micro-short dramas prior to their official launch is becoming increasingly standardized.

1. 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 Series and Films* (Guangdianban Fa [2022] No. 128). The Notice stipulates that competent radio and television authorities shall implement key supervision over key domestically produced online series and films. Online series, online micro-short dramas, online films and online animations that meet one or more of the following conditions shall obtain the *Online Series and Film Distribution License* issued by the competent radio and television authorities in accordance with the law:

(1) Where the amount of investment is relatively large, the specific amount thereof shall be adjusted in a timely manner and publicly notified by the competent radio and television department under the State Council in light of the actual conditions of the development and administration of the online audio-visual industry.

(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 Notice 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. Eligible online micro-short dramas shall obtain the *Distribution License for Online Dramas and Films*, marking that micro-short dramas have entered an era of stringent regulation. However, the Notice does not define the criterion 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 Short Dramas and Implementing the Creation Improvement Plan*, which further clarifies that integrated management shall be implemented for all entities and all links involved in the creation and dissemination of online short dramas in accordance with the principle of consistency in online audio-visual administration. Specific requirements are as follows: All entities operating online short drama services, including short drama-related "mini-programs", shall obtain the *License for Audio-Visual Program Transmission via Information Networks* or be placed under the standardized administration of radio and television administrative departments in accordance with regulations. All online short dramas shall pass the content review of radio and television administrative departments and obtain the *Distribution License for Online Dramas and Films*, or complete the filing formalities for online audio-visual programs in accordance with relevant provisions on online drama and film administration. When licensed works are broadcast online, the unified logo and license number shall be displayed at a prominent position of the program's opening, to be subject to public supervision and full-cycle supervision during the entire online broadcast period. Online short dramas that have not obtained the distribution license shall be gradually removed from the front page and top screen of the platforms.

3. On May 30, 2023, the Department of Internet Audio and Visual Program Administration of the National Radio and Television Administration issued the *Administrative Guidance (on Distribution Licensing and Broadcasting of Online Drama and Film Programs)*. The Guidance stipulates that effective June 1, 2023, newly launched online short dramas shall be submitted for application through the Information Filing System for Key Online Film and Television Programs, and shall only be eligible for broadcasting after passing content review by radio and television administrative authorities at or above the provincial level and obtaining either the *Distribution License for Online Drama and Film Programs* or an online broadcasting filing number. It further clarifies that works holding the *Distribution License for Online Drama and Film Programs* may be distributed on multiple online platforms, while works only obtaining an online broadcasting filing number shall be broadcast only after completing registration with one 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. In 2024, the *Latest Work Notice on Micro Short Drama Filing of a Certain Province* was circulated online. The core content of this notice stipulates that "Effective June 1, 2024, micro short dramas that have not completed review and filing procedures shall not be disseminated online". The notice also classifies micro short dramas on the basis of investment amount, and different levels of micro short dramas correspond to different filing numbers. The specific provisions are 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 online micro-drama randomly selected by the research team.)

(2) "Ordinary Short Web Dramas", namely programs with a total investment ranging from RMB 300,000 (inclusive) to RMB 1,000,000 and not designated as key recommended programs, shall be filed through the Online Audio-Visual Program Filing System of the National Radio and Television Administration. The provincial-level radio and television administrative department shall be responsible for planning filing review and completed program examination. Prior to official online launch, the unique registration and filing number of the program shall be marked on the opening title of the program in the format of: (X) Online Short Web Drama Filing (Year) No. ***.

The research team attempted to locate ordinary micro-short dramas already launched on micro-short drama streaming platforms. After examining a number of such dramas, no such filing was identified in any of the works reviewed.

(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 treated as formal film and television productions, while also posing new challenges for micro-short drama practitioners. The strict supervision over short drama content means that short drama producers or investors shall select works for investment and production in a more rational manner, and may no longer invest in "borderline non-compliant works" as they previously did. Otherwise, the removal of a single work from online platforms may cause heavy losses to investors. The pre-launch filing and review requirement for short dramas will also extend the launch cycle of short dramas, increasing communication and time costs. If producers blindly follow internet hotspots to shoot relevant works, the works may have already missed the hotspot topics when they are officially launched, resulting in investment losses. Therefore, high-quality content and lawful and compliant filing procedures have become key factors for micro-short dramas to gain widespread popularity under the current regulatory environment. Works that blindly chase hotspots, contain vulgar or violent content may eventually be expelled from the short drama market.