Babbitt column | Blockchain information service filing practice FAQ

On March 30, the National Internet Information Office announced the names and filing numbers of the first batch of 197 blockchain information service organizations. From the list, many well-known enterprises have completed the filing, and the services provided by various enterprises also involve supply chain finance. Copyright, traceability, notarization and other fields. For enterprises that have not completed or applied for filing, there may be misunderstandings about the current blockchain information service filing work. The author combines the common consulting problems encountered in practice and answers the relevant questions according to the explanations of the expert leaders. Organize as follows.

What is the role of the 1 blockchain information service filing? Does the adoption of the record mean that the regulatory authorities recognize the compliance of the business?

In practice, there are some practitioners who do not understand the significance of filing, and even over-promoting the registration of the blockchain information system. In response, the person in charge of the website has stated that “the filing is only the registration of the relevant information on the main blockchain information, and does not represent the recognition of its institutions, products and services. No institution or individual may use it for any commercial purpose. ”

In addition, the head of the expert of the National Internet Emergency Center also stated in public that “it is necessary to treat the filing with an open attitude. Do not have the concern of “what will be recorded” or “what will not be filed.” It is only a registration, the field is not complicated. And not registering does not mean you can't find it. If any field is not designed properly, you can feedback and improve."

Therefore, any institution should not over-interpret the role of the “record number”. The filing is only the registration of the relevant information of the main blockchain information service. It is a means of supervision, which means that the blockchain enterprise and its business should be self-disciplined and compliant. On the other hand, it should also take the initiative to accept the review of the regulatory authorities.

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2 How to determine whether it belongs to the subject category that should be filed? For example, in the name of an overseas institution, the blockchain technology service provided in China, such as a wallet, in which case is the main body filed?

In practice, some enterprises have doubts about whether they belong to the main body of the “Regulations on the Management of Blockchain Information Services” (“Regulations”). According to the "Regulations", any block-chain technology or system that provides information services to the public through Internet sites, applications, etc., should be filed.

According to the explanation of the person in charge of the expert, “based on” can be understood as “interaction with the blockchain system”, such as mine pools, wallets, etc.; “Internet sites, applications” are just examples, and there are many forms on the specific network; "Social public", the understanding of the service object can not be limited to the surface meaning. In principle, whether it is the public chain, the alliance chain or the private chain, in principle, it is in the scope of filing; "information service" is not based on the district. The blockchain technology or the blockchain media, market information, community and other services that the system operates are not included in the filing scope.

In addition, according to the "Regulations", engaging in blockchain information services within the territory of the People's Republic of China shall comply with the "Regulations" for filing. However, in practice, the filing of the application subject information in the blockchain filing system website is for the mainland main body, and does not provide a filing port for overseas entities engaged in the above services in China.

By consulting the person in charge of the blockchain information service filing, if the overseas entity engages in the above-mentioned business types and provides services to the Chinese entity, it can report its own situation and data to [email protected], and the relevant responsible person will handle it separately.

3 Enterprises engaged in a variety of business types, such as wallet, technical services and other services, to be separately filed? Is the final record number unique?

In the filing process, if a company is engaged in a variety of business types, after completing the completion of the subject information, various types of services involved in the enterprise may be filed through information addition.

If the enterprise filing review is approved, each service type will obtain a filing number. If the enterprise or a third party needs to check the filing status, you can enter the subject name (company name) or the complete filing number in the system for inquiry. If you enter the record number for inquiry, only the filing status of the service type of the enterprise will be checked, and the record of other service types will not be displayed; if the subject name is entered for inquiry, the filing status of all service types reported by the enterprise will be checked.

4 Which operating procedures need special attention?

(1) Visit the filing system website, register and log in.

Note: One subject corresponds to one account, and multiple subjects cannot share one account.

(2) Fill in the main body information, responsible person information, service information, etc. according to the steps, upload the attachment of the certification materials, submit the application, and wait for the review.

Note: When the application operator fills in the operation-related data, since the data is dynamic, the data at the time of filing the application can be filled in.

(3) If the review is approved, the website will notify the applicant by email or SMS; if the materials need to be revised, the applicant should modify and resubmit the application as required; if it is not within the scope of filing, it will not be filed and notify the applicant. .

Note: The person in charge of the telephone chain information service filing management system by telephone consultation: If the audit fails, the materials need to be revised. The website will notify the filing entity by email or SMS to modify the file. The filing body can log in to the system to view the system. It will list the areas that need to be modified and the relevant instructions for modifying the content. In addition, there is no restriction on the time to resubmit the application, and you can resubmit the application as soon as possible.

5 This time, I have not applied for filing, will there be an opportunity to apply for it later?

According to the relevant person in charge of the blockchain information service filing management system, the filing management system is currently open, and relevant employees and institutions should fill in the relevant information through the filing management system in accordance with the deadlines in the “Regulations” and complete the filing as soon as possible. If the case is not filed in accordance with the prescribed time limit, the Internet information office of the state, province, autonomous region or municipality directly under the Central Government shall make corrections within a time limit according to the duties and responsibilities; if it refuses to correct or the circumstances are serious, it shall be given a warning and shall be imposed a fine of not less than 10,000 yuan but not more than 30,000 yuan. .

6 Can the parent company's technology be filed under the name of the related party? In other words, does the applicant must be a provider of technical services?

The application body of the blockchain information service system shall be the actual provider of the technical service. The enterprise shall fill in the relevant information with the entity actually providing the service and perform the filing formalities.

7 This time, 197 cases have been filed, will the difficulty of subsequent filing increase? Is there a limit to the number of filings?

According to the relevant person in charge of the blockchain information service filing management system, the filing standards are the same, and the number of filings has not been limited. After receiving the filing materials submitted by the applicant, the website will conduct an audit according to the “Regulations” and issue the filing number to the applicants who have passed the examination.

8 other questions

(1) How to check the blockchain enterprises that have been filed?

A: Log in to the blockchain information service filing management system, and enter the subject name of the blockchain enterprise that passed the audit or the complete filing number for inquiry.

(2) Can the registered account information be modified? For example, the account's mailbox, mobile phone number and the like.

A: At present, you can only change the password. If you need to modify the mobile phone number or other account information, you need to log out of the account and re-register a new account.

(3) After completing the filing, does it mean that the data on the blockchain has legal effect?

A: First, the filing only indicates that the business activities of the enterprise belong to the business scope of the blockchain information service. Second, the enterprise has completed the filing according to relevant regulations and requirements, and its data and information have no other legal effect.

(4) If a company finds a blockchain technology service company to do a deposit-based service based on blockchain technology, need to file it?

A: According to the "Regulations", as the developer and operator of the blockchain technology is to be filed, that is, the service provider, and the use of the blockchain technology application does not need to be filed.

The above is a brief answer to the common problems encountered by the author during the practice. I welcome the exchanges with the industry and make suggestions for the development of the industry.

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