[Direct answer]If the materials are incomplete, the applicant will be required to make corrections, but the receiving authority shall not refuse to accept the application solely on the grounds of incomplete items. An application that can proceed to the next stage must at least include three items: the applicant's name and contact information, a description of the content of the requested information, and the format requirements for obtaining the information. In certain cases, if the request relates to the applicant's special needs in production, daily life, or scientific research, a corresponding explanation must also be provided; if the applicant authorizes others to handle the matter on their behalf, additional authorization materials and proof of the parties' identities must be submitted. The "Regulations on the Disclosure of Government Information of the People's Republic of China" (amended on April 3, 2019 and implemented on May 15, 2019) stipulate that the authority shall inform the applicant to make corrections rather than reject the application outright. If the authority deems the content of the application unclear, it shall inform the applicant of the items needing correction and set a reasonable time limit for completion. In conclusion, it is more effective to first fill in the three items of the application form and then supplement the attachments according to the applicant's identity and purpose, rather than simply piling up a stack of copies.

I. Problem background and typical scenarios

When applying for government information disclosure, the starting point is a form, but the difficulty often lies in the column describing the content of the requested information. A common scenario is: the applicant only writes "please disclose all materials of a certain project" or "disclose documents related to a certain matter," but the receiving authority cannot locate the specific document number, issuing authority, or creation date based on this description. As a result, the authority issues a correction notice requiring the applicant to provide a name, document number, or other descriptive information for easy retrieval. This back-and-forth process consumes part of the 20-day response period. Another common issue involves identity and purpose verification. Natural persons must attach identity proof, while legal persons or other organizations need to provide business licenses or unified social credit code certificates along with authorized representatives' power of attorney. If the applicant needs to explain the purpose of the request, such as for litigation evidence, rights protection, or research, they must specify the purpose and attach supporting materials. Submission methods also affect the list of required materials. For mail submissions, the envelope, mailing receipt, and receipt date determine the start date of the response period; for online submissions, the system's receipt notification, uploaded document list, and submission timestamp serve as equally important proof; for in-person submissions, receipt notifications and sign-off records are essential. Many applicants only save the response letter but not the submission proof, only to realize later that they cannot verify the start date of the appeal or litigation period when they disagree with the response. Another scenario arises after the response: if the authority rejects the request on grounds such as the information not belonging to its jurisdiction, the information not existing, or involving third-party rights, the applicant may want to verify what exactly was requested and how the authority conducted the search. However, they later discover that the application form was vaguely described and the attachments were incomplete, making it difficult to pinpoint the disputed content. These scenarios of saving time on form filling but facing troubles later often stem from failing to reverse-engineer the required materials based on the receiving authority's requirements before submission.

II. Key points of contention

Regarding an application, disputes typically focus on three aspects, each of which requires different responses. The first concerns the clarity of the description. Applicants believe that simply stating the item's name is sufficient, while authorities require providing the document number, issuing authority, year of creation, or a descriptive summary to facilitate retrieval. This is not an intentional challenge: retrieval must rely on identifiable clues, and overly broad descriptions may prevent authorities from determining whether they hold the requested materials or which department produced them. Disputes often arise over the "three needs": whether the application relates to the applicant's own production, daily life, or research needs. According to the guidelines established by the "Regulations on the Openness of Government Information of the People's Republic of China" (amended on April 3, 2019 and implemented on May 15, 2019), such explanations should be included in the application. If the description is vague, authorities may require supplementary materials. The second aspect concerns whether supplementary materials constitute a new application. After authorities issue a supplementary notice, applicants must submit the required materials. Key disputes arise over how the response period is calculated, whether supplementary materials count toward the deadline, and the consequences of failing to supplement on time. A reasonable approach is to separately record the date of delivery of the supplementary notice, the date of mailing the supplementary materials, and the date of receipt, rather than treating supplementation as a new application. The third aspect concerns the legal remedies after a dissatisfactory response. If the response is overdue, inconsistent with the actual application, or results in a decision of non-disclosure, applicants may file an administrative review within the statutory timeframe. If they still disagree with the review outcome, they can initiate administrative litigation. The time limits, receiving authorities, and review scopes differ between the two pathways. The "Administrative Review Law of the People's Republic of China" (effective January 1, 2024) and the "Administrative Litigation Law of the People's Republic of China" (amended on June 27, 2017) govern these two processes separately. Choosing the wrong legal path often causes more headaches than missing materials. Only when all three aspects are addressed can the application progress from submission to enforceable accountability.

III. Professional analysis by Hengluo Lawyers

When reviewing an application package, it is advisable to proceed from the perspective of the receiving party: first, check whether the information can be located; then verify the applicant's identity; and finally determine the appropriate retrieval method. The first step, locating the information, relies on the description provided in the application form. When reformatting documents related to a specific matter, it is crucial to include the full name of the issuing authority, the document title or reference number, and the approximate year of issuance, so that the authority can easily retrieve the document. If the reference number cannot be identified, at least clarify the distinguishing features of the document, such as the specific plot of land, project name, or batch number involved. A thorough description of the information will minimize the likelihood of subsequent correction notifications. The second step, verifying the applicant's identity and authorization documents, requires natural persons to verify their ID documents and contact information, while legal entities must check their registration certificates, authorized representatives' authorizations, and stamped application materials. If a third party is handling the application, the power of attorney must clearly specify the scope of authority and not simply state "full authority to handle all matters." All materials must match in name, document number, and date, and the relationship between copies and originals must be clearly explained. The third step, determining the retrieval method, is often overlooked. Paper mail, email, pickup in person, or access to original documents each require different processing steps and costs. If the application form is left blank or ambiguous, there will be frequent confirmations during the response phase. The parties often disagree at this step: applicants emphasize having already submitted the form and requiring the authority to proactively retrieve it, while the receiving party focuses on the searchability of the description, verifiability of the applicant's identity, and selectivity of the retrieval method. Key supporting materials include the original application form, submission receipts, correction notifications, and response letters, rather than retroactively written explanations. Evidence types are divided into four categories: the application group reviews the application form and attachments; the identity group checks ID documents and authorizations; the submission group reviews mailing receipts or online receipts; and the response group reviews response letters and delivery records. When entering the judicial review stage, the calculation of service periods and deadlines also follows the rules of the *Civil Procedure Law of the People's Republic of China* (amended on December 24, 2021 and implemented on January 1, 2022), a step often overlooked.

IV. Practical suggestions and legal basis

Divide the preparation process into two stages before and after submission to ensure a more stable approach than rushing to gather materials right before the deadline. There are three key tasks to complete before submission: 1. **Define the description**: Write down as much information as possible about the required documents, including their titles, document numbers, issuing authorities, and creation dates. If the document number cannot be obtained, provide a descriptive explanation. 2. **Prepare attachments**: Gather all necessary documents based on the application type, including identity proof, power of attorney, and purpose statement. Mark copies as "consistent with the original" and keep one copy for your records. 3. **Select the format**: Specify the retrieval method and delivery channel on the application form to avoid additional communication during the response phase. The **Regulations on the Openness of Government Information of the People's Republic of China** (amended on April 3, 2019 and implemented on May 15, 2019) governs the required disclosure items and notification of supplementary materials. If authorities deem the content unclear, they must provide a one-time notice of supplementary requirements and a reasonable deadline for compliance. Three key dates post submission: - **Receipt date or system acknowledgement date** determines the start of the response period. - **Notification date of supplementary materials** resets the deadline for resubmission. - **Delivery date of the response letter** marks the official start of the appeal or litigation period. Record all three dates on a single form and keep copies for each party to avoid scattered records in envelopes, emails, or mobile devices. **Select the correct legal path for appeals**: - If dissatisfied with the response, first file an administrative appeal within the statutory timeframe under the **Administrative Appeal Law of the People's Republic of China** (effective January 1, 2024). - If still dissatisfied with the appeal outcome, file a lawsuit under the **Administrative Litigation Law of the People's Republic of China** (amended June 27, 2017). - Court filing fees are cumulative based on the **Measures for the Payment of Litigation Costs** (effective April 1, 2007) and separate from the application stage's handling fees. Following these steps, all materials lists, deadline milestones, and legal pathways will be organized systematically.

5. Henglu Law Firm's Reminder

There are several points that require much more effort to rectify after the fact than to prepare in advance. Don't be stingy with descriptions: Adding an extra line to specify the issuing authority and the formation year often saves you from having to go through another round of rectification notifications. Don't just keep the reply as evidence: Organize the mailing receipt, system feedback, rectification notifications, and delivery records in a folder in chronological order, and use them directly when calculating deadlines. Don't put off rectification until the deadline: Make a separate note of the reasonable deadline specified in the notification and add it to your schedule. Failure to rectify within the deadline will often result in the application being deemed abandoned. This firmSpecial Service PageAdditionally, a material checklist has been prepared according to the application stages, which can be used to check items off one by one.

VI. Frequently Asked Questions

Q1: If I only fill out the application form with my name and contact information, will the accepting authority register and accept it directly?

Generally, applications are not registered directly based on the complete materials, but applicants are first notified to make corrections within a specified time limit. The application form only includes the applicant's name and contact information, but lacks a description of the required information and the form of obtaining it. In this case, the authority cannot locate the specific information or determine which department produced it. According to the "Regulations on the Disclosure of Government Information of the People's Republic of China" (amended on April 3, 2019 and implemented on May 15, 2019), in such circumstances, the authority should inform the applicant of the items needing correction and a reasonable time limit, rather than rejecting the application outright. The judgment can be divided into two levels: if the items needing correction are descriptions and forms, the application is still within the process; if the correction still fails to clarify the requested information, it may affect the acceptance. In practice, most applications that are returned are because the description is written as disclosing all materials of a certain project, which the authority cannot retrieve. The conclusion is: it is more efficient to complete the three items and submit the application again than to first submit a simple form and wait for the authority to notify you to make corrections, which will save time.

Q2: For the three materials mentioned in the application correction notice, apart from the application form, which other materials need to be supplemented?

In addition to the application form, there are usually three types of supplementary materials required, each of which must correspond to the subject of the application. The first type is positioning materials: the name of the required information, its document number, the issuing authority, or a characteristic description sufficient to distinguish it from other information, such as the plot number, project name, and year of formation; this is the most frequently mentioned item in the supplementary notice. The second type is identity and authorization materials: natural person's identity documents, legal person's registration certificates, and the authorization of the person in charge; for entrusted handling, an authorization letter should be attached, stating the entrusted matters and authority. The third type is a usage explanation: for claims related to their own production, life, or scientific research, etc., the relationship and usage should be clearly described and accompanied by corresponding certificates. It is more reliable to list the three types in a comparison table by applicant, document, and date. The "Regulations on the Openness of Government Information of the People's Republic of China" (amended on April 3, 2019 and implemented on May 15, 2019) requires that supplementary materials be notified once, and applicants should check off each item on the notification list and send it again, which can avoid two or three rounds of back-and-forth communication.

Q3: If I request disclosure of information and am required to pay a retrieval and copying fee, will it be charged by the number of pages or per item?

The two types of fees should be considered separately and not confused with each other. The fees involved in the application for disclosure may include retrieval, copying, and mailing costs, which are usually calculated based on the number of copied pages or data items. The specific standards are subject to the public announcement of the accepting authority. These fees are not the same as lawyer's fees or the case acceptance fees after litigation. If the dispute proceeds to litigation, the case acceptance fees paid to the court are calculated in accordance with the "Method for Payment of Litigation Costs" (implemented on April 1, 2007) based on the amount of the claim, and the losing party shall bear the fees or share them according to the proportion of liability. What really needs to be checked is whether the fees are based on legal provisions, whether receipts have been issued, and whether the circumstances for fee reduction or exemption apply. If the applicant is truly financially disadvantaged, they can apply for fee reduction or exemption in accordance with the regulations. Keep the receipts for the retrieval fees, payment certificates, and response letters on file so that you can have evidence to refute any disputes over the fees in the future. First, clarify whether the fees are calculated by page or by item, and how much each page or item costs, and then decide which method of obtaining the fees is more cost-effective.

Q4: What is the response period of 20 working days after the administrative organ receives the application? From which date will the time period be recalculated after the application is corrected?

The response period starts from the date the authority receives the application. After the applicant makes corrections, the response period is recalculated based on the date the corrected materials are received, rather than the initial receipt date. The response period specified in the "Regulations on the Disclosure of Government Information of the People's Republic of China" (amended on April 3, 2019 and implemented on May 15, 2019) is 20 working days. If the response period needs to be extended, it must be approved by the responsible person and notified to the applicant, with an upper limit on the extension period. The period from the notification of correction being delivered to the date the corrected materials are received is usually not included in the response period. In practice, it's advisable to keep track of the three dates side by side: the initial receipt date, the notification of correction being delivered, and the date the corrected materials are received, each with a copy of the receipt. For those who disagree with the response, the time limit for appealing for reconsideration is governed by the "Administrative Review Law of the People's Republic of China" (implemented on January 1, 2024), while the time limit for suing is calculated according to the rules of administrative litigation. The starting points of the two periods are different, so don't use the same timeline for both. List each node on a separate line, and it's easy to determine whether it's overdue at a glance.

Q5: On that day, first list the document numbers and formation years of the required information. Which application form should I start filling out first?

Today, first list the document numbers and their creation years, then start filling out the application form corresponding to the submission method. Once the required information is identified, the subsequent attachments of identity documents and usage explanations will have a clear focus; if you only write the item name, it's likely that you'll inevitably receive a correction notice. The order of action can be arranged as follows: First, review the existing approvals, contracts, or receipts you have on hand, and copy the document number, issuing authority, and creation year into a row; then confirm the relationship between the applicant and the agent, and based on this, select the natural person version or legal person version of the application form; finally, fill in the form of obtaining the information as either paper mail or electronic delivery, and save and submit the receipt on the spot. The "Regulations on the Openness of Government Information of the People's Republic of China" (amended on April 3, 2019 and implemented on May 15, 2019) requires that the application must include the applicant's information, a description of the required information, and the form of obtaining the information. By completing all three items before submitting the application, you can avoid the need to resubmit the application and supplement the materials later. By defining this row of descriptions today, the framework of the entire application will be established.

This article is written based on the common judicial interpretations in the Beijing area. If the case occurs in other regions, it is recommended to consult local lawyers to verify the regional differences.

If you are currently facing similar problems, it is recommended that you consult a professional lawyer as soon as possible with the relevant evidence materials, to avoid missing the statutory time limits. →Specialised services - legal services·Beijing Hengluo Law Firm

Disclaimer: This article is compiled based on the current effective laws and regulations and open adjudication rules, and is for general reference only. It does not constitute a formal legal opinion on specific cases. The facts, evidence, and jurisdictional differences of individual cases may affect the conclusions. In case of disputes, please consult a practicing lawyer in time.