Learn about how the Markmonitor China Registrar operates in this webinar. Here, Heidi Zhang, Head of Markmonitor China, discusses how Markmonitor China came to be, its relationship to the larger Markmonitor Corporate Domain Registrar, and how using it can help your brand stay compliant with all local regulations when launching your website(s) in China.
Full Transcript, Including Q&A, of the “Learn How Markmonitor China Registrar Can Help Your Global Business” Webinar
Editor’s Note: The following transcript, including the questions and answers section, has been edited for clarity.
Introducing Heidi Zhang and the Markmonitor China Registrar Webinar Agenda
Speaking: Heidi Zhang
Hi, everyone. I’m Heidi Zhang from Markmonitor. I’m very happy to have all of you here today to hear about Markmonitor China Registrar. Markmonitor China Registrar is a young project. We started a couple of years ago and have successfully launched the service.
First, a little bit more about myself. I’m Heidi Zhang, Head of Markmonitor China Registrar. I’m based in Beijing, China. I’ve been with Markmonitor for six and a half years. I’m also in charge of the Markmonitor APAC industry relations.
Let’s look at the agenda today. We will cover why Markmonitor China registrar came to be and then how it happened. We’ll talk about what we did to start the service and launch the service. And then we’ll discuss where Markmonitor China Registrar is now and the next steps we have planned.
How Did Markmonitor China Registrar Come to Be? A History of the Service, Including Information on China’s Ministry of Industry and Information Technology (MIIT) and Internet Content Provider (ICP) Filings
So, as I mentioned, Markmonitor China Registrar is young. It started back in 2017. That’s because in 2017, MIIT, the Ministry of Industry and Information Technology, the highest internet authority in China, announced the new version of the Internet and domain regulations. The version before that was announced in 2004. After 13 years, the regulations and requirements were outdated. That’s why MIT announced the new one in 2017, and it set very clear roles and responsibilities for different players on the internet, for example, the root management and the registries, registrars, and even registrants. So, it’s very clear and it is the latest regulation for now. All the registries, the domain industry, they need to follow that regulation.
And in the new regulation, what affected the internet user and brands most is the ICP (Internet Content Provider) filing and recordal. Because if a company or an individual has a website in mainland China, resolving in mainland of China, then you have to apply for your ICP recordal. It’s a number in the bottom of a website, and it shows that you have informed the government you are operating a website in mainland China. With the new regulation, if the individual or the company has a website live in China, but you don’t have an ICP filing, then you are not in compliance with the regulations.
If you are not in compliance, and MIIT will do an auto check by themselves or people can report incompliance, and if MIIT finds that out, there is the risk that the website will be shut down. That is a very new change. A lot of companies really take this new regulation seriously. And although MIIT gave companies and the internet a lot of time to adjust, all the registrars, registries and internet users, they’re trying their best to stay in compliance.
So, MIIT is the central management in China, but they actually delegated licensing power to provincial communications and administration. For registries, they still have the right to license through MIIT, but for registrars, all registrars go to their own local provincial administration for their license. So, with that happening, a lot of provincial administrations were also in a position of learning. The domain industry is a very niche industry, so they also needed to learn about the policies, about the rules and also different business models. That learning took some time. There were a lot of lessons back in 2018 and through 2020. Let’s move on.
So, when the policy came out, Markmonitor didn’t really have our license in hand as part of a previous plan, so we chose eName to work with as part of our transitional plan, and some of you may have been working with eName or with your DPAs to manage domain names at eName for some time. eName is a local registrar in China. They had their license in hand. And so eName really valued the partnership with Markmonitor and they gave us the highest level of support. They designed their international team to work with us and they also gave us a special communication channel to escalate emergencies or critical questions. We very much appreciate eName’s partnership.
And eName even designed a very unique compliance process mechanism for us. Previously, eName, from my understanding, when they received compliance emails or notice, they would just take actions immediately to either suspend domain names or forward the notice to the registrar and take actions. But for all Markmonitor domain names, they notify Markmonitor first, and without Markmonitor’s consent, they will never take any action against our domain names.
So, for the past years all our domain names with eName have been totally safe. And our clients didn’t really feel any inconvenience or need to manage domain names somewhere else. But it’s a transition plan. We still needed to develop our own solution because getting our own license was always our target goal.
While working with eName, we started to do the investigation to learn how we can have our own license. I still remember it was very difficult at the very beginning because everyone was at a loss and didn’t really know how to deal with that as, at the time, there were no cases of foreign registrars having their own MIIT license in China. Some people even said that it was not possible. But that is also the time when I joined Markmonitor.
This was my first project, and this is like my baby. I talked with the team, and I told them a lot of times that understanding is always the key. China is a very, very big country, and the policies are very complicated. I explained to the team that each rule, each policy, has a background story. MIIT doesn’t really make policies for no reason. There must be something happening behind it, and then they ask registrars to do something, like real name verification, like keeping the data and the records, and sometimes we also need to share some business data with MIIT.
All the regulations, all the requirements, they’re all for a reason. So, we took quite some time to align with the team to understand what exactly MIIT is asking the registrar to do to stay in compliance, especially because we are not a small registrar — Markmonitor China is a corporate registrar, the business nature is different as compared a retail registrar — and then we started designing the system.
The Relationship Between Markmonitor Corporate Domain Registrar and Markmonitor China Registrar
Markmonitor China Registrar system needed to be part of the larger Markmonitor Registrar. The two registrars, they are not completely independent. They needed to somehow talk with each other and share their data points. So, we spent quite some time discussing how we could make that happen — what the system would be like — and then we had the initial design, and with that we went to the Shanghai CA.
Shanghai CA is short for the Shanghai Communications Administration. That is the provincial authority for the license. We talked with Shanghai CA many times explaining what our business model is and why we designed the system as it was, and Shanghai CA also gave us many suggestions and recommendations. We made many adjustments again and again. And finally, we had the final topology and the plan for Markmonitor China Registrar. After that, we spent almost one and a half years in system development and internal testing. And then we registered a couple of domain names for testing purposes to make sure that everything was working as we planned and as we had talked about with Shanghai CA.
And then it came the on-site examination. For the on-site examination, Shanghai CA actually came to our Shanghai office and saw our team and spoke about roles in the team, and then they looked at our system, function by function. It’s very strict because they want to make sure that the system was developed as designed and that all the critical functions are working as they should. For example, the data storage needed to be in China where the real name verification is happening. They also wanted us to show all the demos of different steps of registering a domain name. We actually did the on-site examination three times. So, each time, they gave us some feedback or suggestions to make the steps more clear or make it easier for the client to use. After a few on-site examinations, we passed in the end. That was in October of 2020.
I still remember when we passed the examination. I was seven months pregnant and then that October I had my little daughter our license also came in the same month. I was extremely happy, and I was kidding to my team that if I knew that the baby would come together with the license, I would have had the baby a couple of years earlier, and it wouldn’t have been that long. But 2020 is a very good year for me because we had the license in hand.
So, the timeline began in 2017, then 2018 is when the new policy was implemented, and then we did the research and we started the preparation of the system and internal discussions. And in 2019, we had our Shanghai company founded and had it accredited by ICANN. We had our own IANA ID as it’s an independent registrar, and we had our system developed. In 2020, we had the onsite examination, and we finally had the MIIT licensing in hand. And in 2021, it’s a very important year, we signed the accreditation agreement with VeriSign. That means Markmonitor China, our Shanghai-based registrar, is accredited for com and net registrations, but not .cn.
We understand that .cn is very important in China, and a lot of our clients use Markmonitor services to manage .cn domain names — .cn is critical. CNNIC, China Internet Network Information Center, is the registry for .cn. Back then, CNNIC was in the process of a lot of internal changes. So, they were very slow with accreditation and communications. We did a lot of work to make the accreditation happen. And at the end of 2021, we finally had the accreditation in hand, and that meant we were totally ready to launch the service for Markmonitor China Registrar. After a couple of years of preparation, in 2022 we finally had the service launched.
It’s easy to say that we launched the service. We spent almost seven to eight months in preparation to start that because there was a lot of work in the background. To launch the service, we needed to make sure that our China Registrar remained in compliance with the local regulations, for example, like the data report to MIIT — making sure that is happening every week, and that the system is running stably.
Security is also very critical. I understand that for our clients, security is like the top thing that you have in mind when choosing Markmonitor or Markmonitor China Registrar. And people may wonder, “You have Markmonitor and Markmonitor China registrars, are the systems the same? The engineers, the technical resources, and the stability of the system, are they the same?” And my answer is always, “Yes.” Because we also see security as the most important thing in our work.
Markmonitor China Registrar: The First Fully-Licensed, Foreign-Owned Registrar in China
Markmonitor China is actually the first and only self-developed foreign registrar in China. We developed and we designed our system all by ourselves, and to be honest, during the process we did have a couple of service providers in China reach out to us saying that they could do it for us — do the coding for us or work with us providing some kind of technical solutions. We declined because we think that we need our system to be independent and wholly owned by ourselves. It’s the hardest way, but it’s the safest way. Some people say that when Markmonitor does the thing, when Markmonitor makes decisions, sometimes it may not be the most cost effective, but it definitely should be the most “right,” and I totally agree with that. We’ll only do the right thing. So, designing and developing our own system is definitely an example of that. And the Markmonitor China Registrar shares the same technical resources with the larger Markmonitor registry — the system, the engineers, the testing resources, development resources and everything. The only difference is our China Registrar is deployed on AWS China because that’s part of the MIIT requirements. The system has to be in mainland China and we worked with AWS China to make that happen. And all the data is also stored in AWS China.
The two registrars need to “talk” with each other because we are serving the same clients. We don’t want clients to feel inconvenienced using two systems and two registrars. So, we have made sure that the two registrars can share business data with each other and then talk to each other, sharing the same contact template and other things. And then when it comes to the operational process, we have our own internal trainings to make sure that all Domain Portfolio Advisors are aware of the China Registrar operations including how they can register domain names under the China Registrar, and how to do the real name verification. The real name verification is done by our Shanghai team, so we have many internal communications on that. And then there’s the policy tracking.
In China, sometimes the policies change a lot, so we make sure that we attend important industry meetings. And we have regular face-to-face meetings with the Shanghai CA to ensure that we have the latest news about the changes or updates. And when it comes to the transfers, because there are a lot of domain names managed by eName, when we thought it was time to transfer the domain names over to let the clients can manage their domain names in one portal, we did. We registered a couple of domain names and transferred them to test and make sure that the transfer is very smooth and safe, because we understand that all the domain names clients need to transfer to our China Registrar are high traffic and very important, especially because most of them have their ICP recordals. So, we totally understand how important that is. We communicated with eName about the transfers to prepare them for the upcoming transfers, and internally, our Shanghai team also did a lot to prepare for the transfers.
Now, most of the domain names that were managed by eName have been transferred to Markmonitor China Registrar and only a few domain names remain with eName for different reasons. Some of those could be that the TLD may not be supported in Markmonitor China Registrar, like .co or some other extensions, and there are still a few clients that have their domain names at eName for own their internal reasons. But we have been communicating with them to urge them to transfer their domain names over.
When I say the two registrars can talk with each other, we try to make the domain management easier in one portal for the client. If you look at this picture it helps to understand it. The clients are using the same Markmonitor portal that they’re familiar with, the portals stay the same. Clients still use their own account and password to log in and have access to both registrars.
And as I mentioned, Markmonitor China has our registrar system on AWS China. The only difference is that in the Markmonitor China system we have data sorted in different buckets. So, we can see this business data is the information you can see in WHOIS lookups. Then, for the system backup, like the continuous C plan and everything, it still needs to be on AWS China and in China. For the real name verification all the contacts, IDs, phone numbers, address, all the data that results when we finish the real name verification, that data is stored in AWS China. So this is how the two registrars work and communicate with each other.
So, it’s been more than two years since we launched the service. You can see where we are now, we are a very independent registrar. Our IANA ID is 3838. And we have our own Shanghai office and company, and our clients and DPAs can choose between Markmonitor and Markmonitor China to manage their domain names depending on their business needs.
Markmonitor China Registrar’s Client Support is Based in China
And it’s as I mentioned — Markmonitor China Registrar is a totally self-developed registrar. The system is very robust and it’s interlinked with Markmonitor Registrar to make the domain portfolio management easier for the clients and DPAs.
At the China Registrar, we now have three members on the team. Two of them are DPAs and specialists and they are based in Shanghai. So, if you have any questions or you need support from your DPA, you can always reach out to your DPA and they will talk with each other and you can get the support and guidelines you need about our China Registrar. And I’m based in Beijing and I’m in charge of the government relations and the policies. We are also working on getting more localized services for our clients. I will talk about that later in another slide. So, right now, we have about more than 1,800 domain names under the Markmonitor China Registrar and more than 95 percent of them are actively resolving and have ICP recordals.
What TLD Coverage Does Markmonitor China Registrar Provide?
Regarding TLD coverage, now we have .cn, .com, .net, and .hub, and three other IDN TLDs. I get the question, “Why don’t we really provide services for other TLDs?” The answer is that we want to and want that to happen, it is part of our plan. As background information, with the Shanghai CA it was very hard to make that happen. The Shanghai CA was very conservative. So, they wanted to give us, like, a probationary period for the first couple of years — they want to see that our business is very healthy, that we do business in compliance with regulations and as promised. They want to see that, and after that, we can ask them to grant more TLDs into our service. So, with that being said, our next step is TLD coverage expansion. I actually went to the Shanghai CA last week and I mentioned that, having more TLDs in our business scope, and they are very open to that.
Also, the registrar license has a term of five years. So next year, 2025, we are hitting our renewal timeline. So next year, we will have our license renewed. I also talked with the Shanghai CA to learn about that process and all that will be required, like the documents, is there going to be another round of on-site examination, and to learn what kind of things we need to prepare because we want to make sure that the process is very smooth. And Shanghai CA said that it is very similar to the initial application and they probably want to make it simplified for us. That’s very good news for us.
Internet Content Provider (ICP) Filings and Recordals Supported by Markmonitor China Registrar
And the last thing I want to talk about is the ICP Recordal Service. ICP is very important for live websites in China. And some for some companies, especially companies outside of China, it’s a little bit challenging to find the very detailed and accurate requirements and process guidelines to receive their ICP. So Markmonitor is looking into that and we plan to offer the ICP recordal services later this year or early next, and then we’ll have a separate webinar about ICP service. If you are interested, pay attention to our emails and you can also reach out to our DPAs to ask about the updates and progress. ICP recordals are not only for websites as mobile internet applications are very popular applications. Apps on phones also need ICP recordals right now in China. That is also challenging. A lot of companies right now working on that. If you have any questions or you want to learn more about the requirements or background or anything, reach out to Markmonitor team.
That is all for the Markmonitor China Registrar webinar, now I’m going to see if you have any questions.
Webinar Question and Answer Session
“Do you think the policy and regulatory environment in China is getting more difficult and tight? Or are they staying about the same?”
That is a very good question. So, I remember back in 2017 when the new regulation just came out, the entire industry had a very difficult time. I was working at a backend service provider company. That was a very hard time for registries and registrars because the policy just came out and a lot of people didn’t really know what to do. Even the MIIT, they just made the new policies, but a lot of questions still needed further explanations and MIIT didn’t really have the answer. So we went through a very difficult time. Now, I think everything is very clear and the new regulations is in place and all the regulations for different players on the Internet are also executing as they should be.
So, I think it’s not going to be more difficult. It’s very stable right now. If you need any instructions or guidelines, read the regulations or talk with the authorities and they should have the answers.
“Do you only offer .cn to China registrants or any other MIIT approved TLDs as well?”
Yes, right now we only offer .cn in China and .com and .net, but we plan to cover more TLDs later because that needs the approval from Shanghai CA. But that is also something we want to see to happen. We will try to make it come true probably next year.
“We have some domain names registered with Alibaba registrar. Can it be transferred to the Markmonitor China entity?”
Yes, we have a lot of cases transferring domain names from all different registrars, either in China or outside of China.
“Are non-Chinese companies looking at this as an opportunity to reach Chinese Internet users or are there other reasons to use this service?”
I think that the short answer is yes. Because the Markmonitor China Registrar is not only for the Chinese clients, but also for global clients. It’s for the integrity of your domain portfolio worldwide. For example, global companies, you may have a business in China and then you have a .cn domain name or com domain name website in China. Then you will need to use Markmonitor China registrar service. So, you can see that Markmonitor China Registrar is a part of the larger Markmonitor service. Although Markmonitor Inc. is very big and Markmonitor China is relatively small, it’s very important to make sure that you can have all your portfolio in one place and in compliance with the local regulations.
“Do I have to use Markmonitor China to register my brand’s .cn domain names or only once we are ready to launch our website?”
That’s a very good question. It’s totally dependent on your own needs because different companies have their own situations. When you want to register a domain name and when you want to activate the domain name, it’s business decisions. If you don’t really have the website ready, that is you don’t really want your domain to resolve in China, you can still have your dossier and domain names with Markmonitor Registrar that’s totally fine and is in compliance. If you want to have your website in China resolve, then you need to think of transferring out the main name, like your standard .com, or registering the domain name with Markmonitor China.
Upcoming Webinars for Brands That Do Business in China
Ok, so for upcoming webinars like on the ICP service, we’re going to have our webinar sometime in early 2025. If you’re interested in that, or if you have any questions you want to hear answered in the webinar, please let us know.
We’re going to have another webinar about how brand registries operate in China next week. It’s also related to the China regulations and policies. If you are interested in that, please join. We’ll have guest speakers from ZDNS and CentralNic. They both are very experienced in registry operations and very familiar with the local regulations. So, we will talk about more of the local regulations from the registry operation perspective, especially for the brand registry, if you want to actually use your domain names to register second level domain names, you need to work with a brand registrar.
Thank you, everyone, for attending. Goodbye.
