This guide is for complainants and respondents in Chinese domain disputes. If you have received a CNDRP notice, go straight to the response section — the deadline is 20 calendar days. If the domain was registered more than three years ago, read the three-year limit first.
Quick answer: what the CNDRP is and what it can do
The CNNIC Domain Name Dispute Resolution Policy (CNDRP) is the administrative procedure for resolving disputes over .cn and .中国 domain names. A complainant must prove three elements: the domain is identical or confusingly similar to a name or mark in which the complainant has civil rights; the registrant has no right or legitimate interest; and the domain was registered or used in bad faith. The response deadline is 20 calendar days from formal commencement. The panel decides within 14 days of its constitution, and the decision is enforced after 10 days unless a court or arbitration body has accepted the dispute. Complaints are not accepted if the domain has been registered for three years or more at the time of filing. The only remedies are transfer or cancellation; there are no damages.
Key facts at a glance
| Fact | Detail |
|---|---|
| Policy | CNNIC Domain Name Dispute Resolution Policy (CNDRP), effective 18 June 2019 |
| Scope | .cn and .中国 (Chinese domain names) |
| Test | (i) identical/confusingly similar to a name or mark in which the complainant has civil rights; (ii) no right/legitimate interest; (iii) registered or used in bad faith |
| Three-year limit | Complaint not accepted if the domain has been registered for 3 years or more |
| Response deadline | 20 calendar days from formal commencement |
| Panel decision | Within 14 days of constitution |
| Enforcement | 10 days after decision unless court/arbitration accepted |
| Providers | CIETAC, HKIAC, WIPO, ADNDRC |
| Fees | HKIAC: CNY 8,000–16,000 single panelist; CNY 14,000–24,000 three panelists |
| Language | Chinese (default) |
| Remedy | Transfer or cancellation; no damages |
| Typical timeline | About 60 days |
What is the CNDRP?
CNNIC and the .cn / .中国 namespace
The .cn country-code top-level domain and the Chinese-script .中国 are managed by the China Internet Network Information Center (CNNIC). The CNDRP is incorporated into the domain registration agreement. By registering a .cn or .中国 domain, the registrant agrees to participate in the administrative proceeding if a complainant asserts the three elements.
The 2019 policy
The current CNDRP has been in force since 18 June 2019, replacing the 2014 policy. The 2019 version tightened some procedural rules and aligned the policy with international practice while retaining distinctive Chinese features.
Providers: CIETAC, HKIAC, WIPO, ADNDRC
CNNIC accredits dispute-resolution providers. The established providers include:
- CIETAC (China International Economic and Trade Arbitration Commission), through its domain-name dispute-resolution centre / Online Dispute Resolution Center.
- HKIAC (Hong Kong International Arbitration Centre).
- WIPO Arbitration and Mediation Center (accredited since 2019).
- ADNDRC (Asian Domain Name Dispute Resolution Centre).
Each provider has its own Supplemental Rules and fee schedule.
.cn dispute? The 20-day clock and the three-year limit decide whether you have a case. We handle CNDRP cases through all four providers. Book a CNDRP review →
The three-year limit: the first filter
Article 2 and the 3-year rule
Quick answer: Under Article 2 of the CNDRP, a complaint is not accepted if the disputed domain name has been registered for three years or more at the time of filing. This is a jurisdictional bar, not a discretionary factor. If the domain is older than three years, the CNDRP is unavailable.
This rule is one of the most important differences between the CNDRP and the UDRP. Under the UDRP, there is no time limit: a complainant can file years after the domain was registered. Under the CNDRP, the clock starts at registration and runs for three years. After that, the complainant must go to court or Chinese arbitration.
What to do if the domain is older
If the domain is older than three years, the options are:
- Chinese court proceedings under the relevant civil and trademark laws.
- Chinese arbitration if the parties have an arbitration agreement.
- Negotiation with the registrant.
A CNDRP complaint filed outside the three-year window will be rejected at the compliance stage.
Is the domain older than three years? The CNDRP may not be available. We assess the court route and the evidence needed. Discuss your options →
The three CNDRP elements
Identical or confusingly similar to a name or mark in which the complainant has civil rights
The first element is broader than the UDRP. The CNDRP protects a “name or mark in which the complainant has civil rights” — not only a registered trademark. This can include:
- Registered trademarks (Chinese or foreign).
- Trade names.
- Well-known unregistered marks.
- Personal names.
- Other civil rights recognised under Chinese law.
The threshold is similar to the UDRP: the domain must be identical or confusingly similar to the name or mark. The .cn or .中国 suffix is disregarded.
No right or legitimate interest
The complainant must show the registrant has no right or legitimate interest in the domain or its principal part. The CNDRP recognises the same safe harbours as the UDRP:
- Bona fide use, or demonstrable preparations to use, the domain in connection with a genuine offering of goods or services before notice of the dispute.
- Being commonly known by the domain.
- Legitimate noncommercial or fair use.
The burden shifts to the respondent once the complainant makes a prima facie case.
Registered or used in bad faith
Quick answer: The CNDRP requires bad faith in registration or use, not both. This is a critical difference from the UDRP’s conjunctive “registered and used” test. A domain registered innocently but later used to target the complainant can satisfy the third element.
The CNDRP lists bad-faith circumstances, including:
- Registering primarily to sell, rent, or transfer the domain to the rights holder or a competitor for profit.
- Registering to prevent the rights holder from reflecting the mark in a corresponding domain.
- Registering to damage a reputation or mislead the public.
- Using the domain to attract, for commercial gain, internet users by creating confusion.
The “or” matters. It gives complainants a route that the UDRP does not, and it warns respondents that an innocent registration does not immunise later abusive use.
The CNDRP is not the UDRP. “Civil rights” and “registered or used” change the analysis. Ask us to assess your case →
CNDRP vs UDRP: the critical differences
| Feature | CNDRP | UDRP |
|---|---|---|
| Rights basis | Name or mark in which the complainant has civil rights | Trademark or service mark |
| Bad faith | Registered or used in bad faith | Registered and used in bad faith |
| Time limit | Three years from registration | No time limit |
| Response deadline | 20 calendar days | 20 days + 4-day extension |
| Panel decision | Within 14 days of constitution | About two months |
| Enforcement | 10 days unless court/arbitration accepted | 10 business days |
| Language | Chinese (default) | Language of registration agreement |
| Remedy | Transfer or cancellation | Transfer or cancellation |
| Providers | CIETAC, HKIAC, WIPO, ADNDRC | WIPO, Forum, ADNDRC, CAC, CIIDRC |
“Name or mark” vs “trademark”
The CNDRP’s broader rights basis is a significant advantage for complainants who rely on trade names or unregistered marks. A Chinese trade name or a well-known unregistered mark can support a CNDRP complaint even if it is not a registered trademark.
“Registered or used” vs “registered and used”
The disjunctive test is strategically important. A domain registered in good faith but later used to divert customers or impersonate the complainant can be caught by the CNDRP even though it would fail the UDRP’s conjunctive test.
The three-year limit
The three-year limit is the CNDRP’s most distinctive feature. It is a jurisdictional bar, not a discretionary factor. Complainants must file within three years of registration or pursue a different route.
Language and enforcement
The CNDRP defaults to Chinese. This adds cost and time for non-Chinese complainants, who must translate their submissions. The enforcement clock is 10 days, which is shorter than the UDRP’s 10 business days but still gives the respondent a window to go to court.
The CNDRP is faster and cheaper than court, but it has a three-year limit. We match the procedure to the facts. Ask us which route fits →
Standing: who can file
Registered trademarks
A registered trademark — Chinese or foreign — is the strongest basis for standing. The registration must be in force and must cover the goods or services connected to the domain. A Chinese trademark carries the most weight; foreign registrations are accepted but may require more evidence of recognition in China.
Trade names and unregistered rights
A trade name, a well-known unregistered mark, or a personal name can support a CNDRP complaint. The complainant must show that the name is distinctive and that it has civil rights under Chinese law. The evidentiary burden is higher than for a registered trademark.
Civil rights under Chinese law
The CNDRP’s reference to “civil rights” is deliberately broad. It allows complainants to rely on rights that the UDRP would not recognise, including certain personality rights and trade-name rights. The panel assesses whether the right is enforceable and whether the domain interferes with it.
CNDRP standing is broader than the UDRP. We test the rights basis before you file. Assess your standing →
Choosing a CNDRP provider
CIETAC
The China International Economic and Trade Arbitration Commission is the principal domestic provider. Its fee schedule is published on its website. It administers cases in Chinese and has a large panel of Chinese experts.
HKIAC
The Hong Kong International Arbitration Centre is a leading provider. Its fee schedule (in CNY) is:
| Panel | Domains | Total fee (CNY) | Administration fee | Panelist fee |
|---|---|---|---|---|
| Single | 1 | 8,000 | 4,000 | 4,000 |
| Single | 2–5 | 12,000 | 6,000 | 6,000 |
| Single | 6–10 | 16,000 | 8,000 | 8,000 |
| Three | 1 | 14,000 | 6,000 | 8,000 |
HKIAC’s Supplemental Rules require the response within 20 days of the proceedings commencement notice.
WIPO
WIPO has been accredited since 2019 and administers CNDRP cases through its Arbitration and Mediation Center. Its fee schedule is available on the WIPO website. WIPO is a good choice for international complainants who want a familiar case-management process.
ADNDRC
The Asian Domain Name Dispute Resolution Centre is another accredited provider. It operates in Beijing, Hong Kong, Kuala Lumpur, and Seoul. Its fees are comparable to HKIAC’s.
Fee comparison
| Provider | Single panelist (1 domain) | Three panelists (1 domain) |
|---|---|---|
| HKIAC | CNY 8,000 | CNY 14,000 |
| CIETAC | Check current schedule | Check current schedule |
| WIPO | Check WIPO schedule | Check WIPO schedule |
| ADNDRC | Comparable to HKIAC | Comparable to HKIAC |
Provider choice affects fees, language, and case management. We match the provider to the case and the complainant’s needs. Ask us which fits →
Filing a CNDRP complaint
Complaint contents
A CNDRP complaint must include:
- The complainant’s details and authorised representative.
- The disputed domain name(s).
- The rights relied on: registered trademark, trade name, unregistered mark, or other civil right.
- The three-element analysis.
- The evidence, in numbered annexes.
- The remedy sought: transfer or cancellation.
- The certification.
Evidence
Useful evidence includes:
- Trademark registration certificates and proof of use.
- Trade-name registration and trading evidence.
- Screenshots of the respondent’s website, with dates and URLs.
- WHOIS/RDDS records.
- Correspondence showing an offer to sell, blocking, or disruption.
- Evidence of confusion.
- Evidence of a pattern of bad-faith registrations.
Language
The proceedings default to Chinese. Non-Chinese complainants must translate their submissions and evidence. This adds cost and time, but it is mandatory unless the panel orders otherwise.
Fees
The complainant pays the provider’s fee. At HKIAC, the fee ranges from CNY 8,000 to CNY 16,000 for a single panelist and CNY 14,000 to CNY 24,000 for three panelists, depending on the number of domains.
The CNDRP response: 20 calendar days
The deadline
The respondent has 20 calendar days from the formal commencement of the proceedings to file a response. The proceedings commence when the provider sends the confirmed complaint to the respondent.
Extensions
Extensions are available in exceptional circumstances at the provider’s discretion. A proceeding may also be suspended briefly if the parties signal a settlement. Extensions do not materially reset the overall timeline.
Default and panel expectations
If the respondent does not respond, the panel proceeds on the complaint record alone. The panel still applies the full three-element test and will deny transfer if the complaint is deficient. Default is common in phishing cases, but it is not an automatic win. Panels have denied transfer in default proceedings where the complainant failed to prove bad faith independently of the registrant’s silence.
Building a response
A strong CNDRP response focuses on:
- No confusing similarity: the mark is descriptive or weak, the domain’s dominant element is different.
- Rights or legitimate interests: bona fide use, commonly known, fair use.
- No bad faith: priority, genuine reason for the name, no targeting, no commercial gain from confusion.
- The three-year limit: if the domain is older than three years, the complaint should be rejected.
Received a CNDRP notice? You have 20 calendar days. We review the complaint and build a response around the three elements. Book a deadline review →
The panel and the decision
Panel constitution
The provider appoints a single panelist or a three-member panel, depending on the complainant’s election and the provider’s rules.
The 14-day decision
The panel must decide within 14 days of its constitution. This is a short clock. The panel decides on the written record; there is no hearing.
Transfer or cancellation
The panel can order transfer or cancellation. There are no damages and no costs.
Enforcement: the 10-day clock
The decision is enforced after 10 days unless the respondent proves within that window that a court or arbitration body has accepted the dispute. If the respondent files a court action, the registrar awaits the court’s decision.
Court and arbitration routes
The CNDRP expressly allows a losing or winning party to take the matter to the CNNIC-location courts or a Chinese arbitration institution. This is a parallel route, not an appeal. A court can award damages and grant interim injunctions that the administrative procedure cannot.
For complainants who need monetary relief or an injunction against a wider fraud operation, the court route may be preferable, despite the longer timeline and higher cost.
Costs and timeline
| Stage | Typical duration |
|---|---|
| Complaint and compliance | Days |
| Commencement and notification | Days |
| Response | 20 calendar days |
| Panel constitution and decision | 14 days after constitution |
| Enforcement | 10 days after decision |
| Overall | About 60 days |
| Cost item | Amount |
|---|---|
| HKIAC single panelist (1 domain) | CNY 8,000 |
| HKIAC three panelists (1 domain) | CNY 14,000 |
| CIETAC / WIPO / ADNDRC | Check current schedules |
| Translation | Additional |
| Legal fees | Additional |
Illustrative CNDRP themes
Phishing and impersonation
Phishing is the clearest case for a CNDRP complaint. The bad faith is obvious from the domain’s use, and the panel can order transfer quickly. The evidence should be timestamped and comprehensive, including the live phishing pages, spoofed brand elements, and any customer complaints.
The three-year limit in practice
A domain registered in 2020 is no longer eligible for a CNDRP complaint in 2026. Complainants must check the registration date before filing. If the domain is older, the court route is the only option.
Trade-name and unregistered rights
The CNDRP’s broader rights basis allows trade-name owners and unregistered mark owners to file. The evidence must show that the name is distinctive and that the respondent’s use interferes with the complainant’s civil rights.
Default cases are not automatic wins
Panels have denied transfer in default proceedings where the complainant failed to prove bad faith independently of the registrant’s silence. The complaint must stand on its own.
Complainant checklist
- Three-year limit: The domain was registered less than three years ago.
- Rights: Registered trademark, trade name, unregistered mark, or other civil right.
- Confusing similarity: The domain is identical or confusingly similar.
- No legitimate interest: Prima facie case with affirmative evidence.
- Bad faith: Evidence of bad-faith registration or use.
- Language: Chinese translation prepared.
- Provider: CIETAC, HKIAC, WIPO, or ADNDRC; fee ready.
- Evidence file: Numbered annexes with dates and sources.
- Court route: Consider whether court is needed for damages or injunctions.
Ready to file a CNDRP complaint? We test the three-year limit and the three elements before you commit. Start a CNDRP assessment →
Respondent checklist
- Deadline: 20 calendar days from formal commencement.
- Three-year limit: Is the domain older than three years? If so, the complaint may be rejected.
- Rights/legitimate interests: Bona fide use, commonly known, fair use.
- No bad faith: Priority, genuine reason, no targeting.
- Language: Prepare submissions in Chinese or request translation.
- File on time. Do not default.
Received a CNDRP notice? Do not ignore it. Book a deadline review →
How counsel.domains can help
If you are planning a CNDRP complaint, we check the three-year limit, test the three elements, and prepare the Chinese-language filing.
If you have received a CNDRP notice, we review the 20-day deadline, build a response, and assess the court route.
If the domain is older than three years, we advise on Chinese court proceedings and coordinate with local counsel.
counsel.domains Domain name disputes, worldwide. Talk to counsel about a .cn dispute → · [email protected]
Disclaimer: This website provides general information about domain name dispute resolution. It is not legal advice and does not create a professional relationship. Procedures and fees change; check the relevant policy and provider before acting. counsel.domains is not affiliated with CNNIC, CIETAC, HKIAC, WIPO, ADNDRC, or any registry or dispute-resolution provider.