Why AEMaaCS migration may break your compliance in China

For many global companies operating in China, Adobe Experience Manager (AEM) has long been a cornerstone of their digital presence. Organizations that previously invested in a fully compliant setup — establishing a local business entity, obtaining an ICP license, and ensuring MLPS 2.0 compliance — are now looking to modernize by migrating to AEM as a Cloud Service (AEMaaCS).

But there’s a catch: This migration may undermine all the work they’ve done to stay compliant in China.

If you're operating legally in Mainland China, you know how much time and money it took to get there.

You've likely taken the following steps:

• Established a legal business entity

• Rented an office and organize physical operations

• Opened a local corporate bank account

• Went through the bureaucratic process of obtaining official company chops

• Set up proper monthly bookkeeping, tax reporting, and government filings

• Passed annual audits and renew registrations

• Obtained and file an ICP filing

• Registered your setup with the Public Security Bureau (PSB)

• Ensured MLPS 2.0 compliance for your production environment — including:

  • Local hosting

  • Proper data classification and access control

  • Logging, monitoring, and emergency plans

• And finally: maintained, monitored, and proven compliance through day-to-day operations

In terms of costs, ballpark for first-year all-in will $50,000 - $250,000 USD for typical Western company, not counting registered capital (which can add another $50k - $500k depending on local requirements). Timeline for permits and seals is 6 - 18 months realistically if all are done in parallel.

Now, in search of modernization, scalability, and better integration with Adobe’s new stack, you’re considering a move to Adobe Experience Manager as a Cloud Service (AEMaaCS), and most likely with Edge Delivery Services.

But unless you take China into account early in your migration plan, you may unintentionally invalidate your ICP, breach cybersecurity law, or drop below MLPS compliance standards.

AEMaaCS brings scalability, automation, and modern DevOps pipelines — but it’s built with a global model, not a China-first mindset. When you move to AEMaaCS, your content authoring, publishing pipeline, and delivery infrastructure are hosted in data centers outside of Mainland China.

That’s where the friction begins, because for your China market, it strictly means:

• ICP Violation: ICP filing requires content to be hosted on servers located within Mainland China. Once you move your site abroad, your ICP becomes invalid.
  
  

• MLPS Violation: The MLPS 2.0 framework mandates data residency and real-time monitoring. Hosting outside China breaks both.
  
  

• GFW latency and blocking: When you migrate your AEM stack to Singapore or Tokyo, you're also moving your infrastructure outside the Great Firewall (GFW). That means your Chinese users now have to cross a heavily filtered and often throttled network barrier to access your services.

That’s right: AEMaaCS is optimized for global speed, not for China compliance. And that means your carefully built, legally compliant China presence may not survive the migration intact.

Adobe's AEMaaCS integrates Edge Delivery Services as a fundamental layer for content delivery and rendering, designed to accelerate performance across global markets. By default, Edge Delivery Services leverages two redundant global CDNs, including Fastly, for speed, resiliency, and scale.

However, global CDNs are not suitable for serving users inside Mainland China. They are not licensed under Chinese law, lack local points of presence, and cannot provide ICP-compliant edge delivery. As a result, content served through these CDNs may be throttled, blocked, or entirely inaccessible due to China's regulatory and network controls.

You might think, "We’ll just add a local Chinese CDN." But to do that, you need to serve your content within Mainland China — and Adobe’s SaaS does not support in-China hosting. That creates a catch-22:

• Edge Delivery Services doesn’t work reliably in China

• You can’t swap in a local CDN unless you host locally

• You can’t host locally with AEMaaCS

Long story short, probably now you're stuck with a delivery setup that cannot be made compliant, and cannot be optimized for Chinese users.

If you look closer, you will notice that not only is using AEMaaCS with Edge Delivery Services (and the Universal Editor) not compliant with Chinese law, but it cannot even be used by teams based in China.

For example:

• Universal Editor often depends on tools like Google Docs and Sheets, which are blocked in China.

• Preview URLs and publishing APIs may be slow or intermittently inaccessible.

• Developers collaborating through GitHub from China may experience network latency

More about the China market specificities you may find in Adobe Experience Manager - China FAQ page.

Hosting your AEMaaCS instance in Singapore or Japan can immediately void your ICP license and disqualify your setup from MLPS compliance. The moment you switch, your previously compliant infrastructure becomes a liability.

Even if your global engineering team has already flagged issues with compliance in the China region, there’s a real risk that these issues are being deprioritized during your AEMaaCS migration.

Let’s be clear:

• Your compliance status in China is hard-earned.

• Don’t risk losing it due to a misaligned global rollout or a “we’ll handle it later” migration plan.

ICP licenses, MLPS 2.0 compliance, and local performance optimizations aren’t just boxes to check—they’re critical enablers of your presence in Mainland China. Hosting your site out of Tokyo or Singapore might satisfy your global infrastructure model, but it breaks your alignment with Chinese law and can invalidate your presence in this market.