The China National Intellectual Property Administration (CNIPA) is transitioning to the exclusive use of XML format for all patent e-filings. While Word and PDF formats were previously accepted, CNIPA has begun a phased rollout of mandatory XML filing, which started for certain application types on 1 October 2025, and will extend to all patent e-filings from 2026. Key implementation details are as follows:
Core Timelines & Mandatory Rules
- From 1 October 2025: For patent applications filed on or after this date that require any of the following procedures — Priority Examination, Rapid Examination, PPH (Patent Prosecution Highway), Deferred Examination, or Collective Examination — submission in XML format is mandatory.
- Starting in 2026: The CNIPA's e-filing system will be progressively upgraded in 2026 to accept only XML format for patent e-filings.
Scope of Applicable Patent Applications
- Covered Types of Applications: The mandate covers Chinese national applications for inventions, utility models, and designs, as well as re-examination, invalidation, and PCT national phase entry applications.
- Documents Mandatory in XML: Request Form, Application Documents (e.g., abstract, description, drawings, general description for design patents, etc.), and Replacement Pages of Amendments.
Consequences of Non-Compliance & Exceptions
- Failure to submit the required application or subsequent amendment documents in XML format will be considered a voluntary waiver of the right to benefit from the aforementioned accelerated or special examination procedures.
- Exceptional Documents: Evidence documents, Comparison Pages for Amendments, Sequence Listings, and Others not specified as mandatory above can still be submitted in other acceptable electronic formats (e.g., PDF).
Resources & Responsibilities
- Applicants and patent agencies can use the official tools provided by the CNIPA or compliant third-party tools to generate XML files.
- Applicants and agencies bear the responsibility for performing necessary checks to ensure the accuracy of the content in the submitted XML files.
Advantages
According to the CNIPA Annual Report 2024 (published in August 2025), the average examination period for invention in China — measured from the start of substantive examination to case closure — was shortened to 15.5 months. As XML-formatted documents can be directly processed by the patent examination system without additional data conversion, the full adoption of XML is expected to further shorten examination timelines and improve overall consistency.
On the other hand, the shift to XML will impose additional burdens on applicants and patent agencies. More time will be required for format conversion and document verification, potentially increasing initial filing costs.