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The mental health risks of internal migrants have become increasingly prominent, yet traditional diagnosis and treatment pathways face structural barriers including the uneven distribution of medical resources, insufficient service accessibility, high time costs, and the stigma surrounding mental health that prevent them from adequately addressing the mental health problems of this population. Cultural participation, as a low-threshold, low-stigma daily practice, may provide preventive support before mental health conditions deteriorate through fostering social connection and cultivating a sense of belonging and identity. Although public cultural services are not designed exclusively for internal migrants, their universally accessible and daily-embedded institutional characteristics may offer this population an alternative pathway for mental health support that complements the barriers to formal help-seeking. The Public Cultural Service Guarantee Law of the People's Republic of China, as the foundational legislation in this field, establishes a normative framework centered on guaranteeing basic cultural rights and interests, enriching spiritual and cultural life, and advocating healthy and civilized activities. Thus it provides normative space for public cultural services to undertake health promotion functions. In practice, however, resource allocation and performance assessment remain heavily oriented toward physical indicators such as the number of venues, facility size, and event frequency, with insufficient attention paid to whether service content matches users' actual needs, whether access arrangements accommodate diverse groups, and whether participation processes are conducive to social interaction and emotional regulation. Under this logic, internal migrants are mostly regarded as service recipients rather than subjects of cultural participation, constraining the release of the mental health support potential that public cultural services inherently possess. Accordingly, the cultural participation opportunities, expression rights, and identity recognition needs of internal migrants should be incorporated into the framework of legal protection, and public cultural services should be transformed from general cultural supply into institutionalized public resources oriented toward mental health prevention.