Policy Analysis on China’s Civil Society Organizations

Three policies emerged around 2017 that have a significant impact on the development of civil society organizations (CSOs): the Law on Administration of Activities of Overseas [Foreign] Nongovernmental Organizations in the Mainland of China (hereafter the FNGO Law), effective the first week of the year; the Charity Law, effective September 2016; and the Opinion on the Reform of the Social Organization Management System and Promotion of the Healthy and Orderly Development of Social Organizations (hereafter the Reform Opinion), jointly issued by the General Office of the Chinese Communist Party (C.C.P.) Central Committee and the General Office of the State Council in August 2016. This report offers description and analysis of the effect these three policies have each had on China’s 700,000 CSOs¹ and on the unknown number of civil organizations that are not registered with any office of civil affairs.

Main Trends

The implementation of the Charity Law, the FNGO Law, and the Reform Opinion sent a signal that the Chinese government had “legalized” its monitoring of domestic and foreign NGOs and that the “political suppression” of the time before such legislation was over. Specifically, this means: (1) FNGOs wishing to carry out activities in China in the long term must register with a representative office and must accept the supervision of public security and an organization in charge of operations; (2) “databases of social organizations which present with suspect behavior” (suspect lists) now have an important function; (3) charitable fundraising, government purchases, foreign aid, and all other items related to the human and financial resources needed to sustain and grow an organization will go to CSOs that have been officially recognized as “legal” and “qualified”; and (4) independent, unregistered civil organizations will be marginalized and may be considered illegal and banned.

Respectively speaking, first, registered and unregistered FNGOs each face their own challenges. At present, the greater half of FNGOs registered with representative offices were already registered with an office of civil affairs before the emergence of the FNGO Law. The primary reason that many FNGOs have difficulty registering with a representative office is that it is hard to obtain approval from an organization in charge of operations. These FNGOs must spend a great deal of time preparing documentation and communicating with the relevant government offices, in addition to finding a suitable organization in charge of operations. As for FNGOs that have registered with multiple representative offices, it is a challenge to manage these different offices as a whole. These FNGOs also face particular problems in the process of their practical development work.

Second, the effects of the Charity Law are just beginning to be felt. More than a year after the Charity Law went into effect, supporting implementation documents have been issued one after another, yet recognized charitable organizations comprise less than 0.5 percent of CSOs. On the one hand, the threshold for recognition of charitable organizations is fairly high; on the other, CSOs are not especially proactive about applying for recognition. There are FNGOs which, having operated in China for several years, have established charitable organizations in addition to registering with representative offices. Once they have met the qualifications to collect charitable donations, they may fundraise in mainland China. This means that the Charity Law benefits the legal fundraising engaged in by some organizations that run public welfare activities. Illegal fundraising was cracked down on in 2017. There is no real evidence that the situation has improved for the typical public welfare organization. Even some legal “hot” charitable fundraising products came under public scrutiny. Charitable organizations are still having trouble fundraising and garnering sufficient credibility.

Third, these policies and laws reinforce the strict management of CSOs. There are four parts to the monitoring and control of CSOs: (1) the establishment of “suspect lists” by all local civil affairs bureaus in order to manage CSOs; (2) the expansion of law enforcement and supervisory powers over illegal CSOs on the mainland; (3) the tightening of the CSO registration process; and (4) the punishment of politically sensitive CSOs. Data and case studies show a substantive negative effect on the existence and growth of some CSOs. At the same time, other CSOs have used systemic channels and publicity to demand that the government reverse administrative punishment. The clarification of laws and policies may become a weapon of self-preservation for CSOs.

A detailed analysis follows.

Slow Process for FNGOs to Register with a Representative Office, Most Still Unregistered

Registration and Controlling Bodies

According to the data, there are about 1,000 FNGOs in China currently carrying out long-term activities. Adding organizations that are developing short-term partner projects, the total falls between 4,000 and 6,000.² Vice Foreign Minister Fu Ying has indicated that there are over 7,000 FNGOs in China.³

Yet in the first year of the FNGO Law (January 1 to December 31, 2017) just 259 FNGOs registered with 305 representative offices across 26 provinces. Fifty-seven percent of these 300-odd representative offices are engaged in economic and other mutual-benefit activities, far more numerous than social welfare organizations. Among the public welfare FNGOs that comprise the other 43 percent of the total, most are involved in poverty alleviation, [also] a general trend among representative offices.⁴

Since the promulgation of the FNGO Law, FNGO registration management bodies and organizations in charge of operations have been fairly active in putting forward supporting policies and implementation guidelines. In August and September of this year, two organizations in charge of operations, the State Council Leading Group Office of Poverty Alleviation and Development and the State Forestry Administration, issued supporting work methodologies delineating the scope of cooperation with FNGOs.

According to a study of the first five months of the FNGO Law by Beijing Normal University’s China Philanthropy Research Institute⁵, representative offices that were already registered with civil affairs bureaus were able to smoothly transition to management under public security. Economic organizations registered with offices of industry and commerce also had an easier time applying for registration. Many FNGOs’ registration requests were approved by a registration management body after two months of communicating with an organization in charge of operations and preparing documentation. Prior to the FNGO Law, 34 percent of newly registered representative offices had not registered with either an office of civil affairs or an office of industry and commerce. They found other means of carrying out activities, or else simply did not register. The implementation of the FNGO Law has clearly encouraged FNGOs to carry out activities under a registered identity.

Representative Offices and Cross-Regional Activities

Open data show that at present 26 FNGOs have established multiple representative offices. Article 18 of the FNGO Law states that “representative offices of overseas NGOs shall operate under their registered names when carrying out activities within their operational scope and area.” According to the Handbook for the Registration of FNGO Representative Offices and the Documentation of Temporary Activities (Handbook), an FNGO may choose to register the location of its activities “within the respective provincial administrative district or inclusive of and exceeding [the boundaries of] said district” on the basis of the representative office’s operational scope and the practical reality of carrying out activities. This means that an FNGO’s formally registered region of activity may exceed the jurisdiction of its registration management body. Organizations in charge of operations currently take three forms: those under the direction of national-level ministries and commissions, those established in Beijing and Shanghai, and those under the direction of offices of industry and commerce. The established location of the FNGO of one of these organizations in charge of operations generally have a multi-province region of activity.

Research shows that an FNGO’s ability to carry out activities beyond the province of its local registration often depends on the organization in charge of operations. For example, the organization in charge of operations for the Chongqing office of the Australian Charity Aid Service Company is the Chongqing Bureau of Civil Affairs. In addition to the city of Chongqing, its scope of operational activities includes Yunnan Province.⁶ According to the research, the reason some organizations have established multiple representative offices is to prevent their funds from being cut off due to failure to successfully register with a higher-level office. Going forward, these FNGOs will also face the challenge of managing these disparate representative offices.

487 Temporary Activities Documented in 2017

Besides establishing a representative office, FNGOs may also choose to document temporary activities. 487 temporary activities were documented in 2017. There are two circumstances under which an FNGO may document a temporary activity. The first is that they are running the temporary activity only and do not plan to operate in China long-term. The other is that the organization is still in the process of applying for registration with a representative office. According to the data, of the 99 temporary activities documented between January and May 2017, 57 percent had relatively long timeframes of six to 12 months. Oxfam Hong Kong, Partnership for Community Development, World Vision International, and Misereor, which registered representative locations after this period of time, continued to document temporary activities after May. Clearly, many FNGOs are documenting temporary activities as a stopgap while they wait for their registration to be processed.

In Age of Charity Law, Partnership Between Government and Charitable Organizations Still Pending

Since the Charity Law took effect in September 2016, the relevant government departments have issued 15 supporting documents covering 10 aspects of the law, including: (1) direct registration; (2) recognition of charitable organizations; (3) qualifications for public fundraising; (4) online public fundraising; (5) management of charitable trusts; (6) innovation of equity donation; (7) annual disbursements and administrative expenses; (8) preferential tax policies; (9) supervision by civil affairs bureaus; and (10) the system of CSO management.⁷

Some scholars are concerned that overbearing fundraising guidance from the government will damage the autonomy of social agents. They recommend that the government establish partnerships with charitable organizations, empowering the charity sector to build public trust.⁸ People’s Political Consultative Conference delegate and Tsinghua University School of Public Policy and Management professor Wang Ming has stated that under the Charity Law the new state-society relationship is structured such that “the government controls the platform, the platform faces the organization, public society is supervised and organizations act in accordance with the law.”⁹ Traits of the registration and recognition of charitable organizations and the state of charitable fundraising are explained below.

Charitable Organizations Slow to Be Recognized, Less than 0.5 percent of CSOs

As of December 31, 2017, 3228 charitable organizations have confirmed registration throughout China, including 817 fundraising organizations.¹⁰ It is estimated that charitable organizations comprise less than 0.5 percent of all CSOs.

Charitable organizations with confirmed registration are concentrated in the economic centers of Beijing, Shanghai, and Guangzhou. Relatively few have registered in the southwest or northwest. The majority of these organizations are the charitable arms of corporations. They have a wide operational scope, primarily covering philanthropic poverty alleviation, support for the elderly and orphans, financial aid for students and the disabled, and disaster relief. A number of them are specialized as educational foundations. Several community foundations have cropped up in Shanghai. These organizations conform to the local government’s policy guidance on cultivating community CSOs and social administration. However, analysis of the charitable organizations that successfully registered in the third quarter of 2017 shows that some social organizations and social service organizations were confirmed as charitable organizations while in the process of registration. According to the provisions of the Charity Law, these organizations will be able to apply for public fundraising credentials.

The Charity Law grants charitable organizations the statutory right to fundraise on the mainland, but according to the FNGO Law registered FNGOs cannot engage in fundraising activities. However, there are cases indicating that FNGOs can establish charitable organizations in mainland China by other means.

Case Study: Establishment of Charitable Organization in Mainland China by an FNGO

The Beijing Wing Ching Rural Development Foundation was founded in 2013 by Chan Hing-wan and Yang Tuan, Secretary-General of the Hong Kong Wing Ching Foundation and Deputy Director of the Chinese Academy of Social Sciences Center for Public Policy Research, respectively. The foundation was confirmed as a charitable organization on November 17, 2016 and currently qualifies for charitable donation tax deductions. It does not yet have public fundraising credentials. The foundation’s RMB 20 million seed fund came from the Hong Kong Wing Ching Foundation. In 1994 the Shih Wing Ching Foundation was registered as a charitable organization in Hong Kong. All of its funding comes from Hong Kong businessman and philanthropist Shih Wing Ching. In 2011 the organization established the Board of Management of the China Association for NGO Cooperation (CANGO) Shih Wing Ching Rural Development Special Fund. On November 23, 2017, the Beijing representative office of the Shih Wing Ching Foundation (Hong Kong) successfully registered with the Beijing Public Security Bureau. Its organization in charge of operations is the Chinese People’s Association for Friendship with Foreign Countries. The Shih Wing Ching Foundation (Hong Kong) simultaneously acquired status as a domestic charitable organization and an FNGO. This illustrates how the organization established its organizational identity on the basis of Chinese policy toward social organizations.

Charitable Fundraising Faces Tests of Professional Autonomy, Government Supervision, and Public Scrutiny

One of the hottest issues in the era of the Charity Law is the focus on charitable organizations in the supervision of charitable fundraising. The Ministry of Civil Affairs has already confirmed the first group of 13 online charity information platforms. A second group of 10 selected platforms was announced on January 8, 2018. With regards to the official selection of online charity information platforms, Professor Wang Ming believes that 13 platforms is already too many and that the number should be reduced, while Professor Jia Xijin says that governments do not cull platforms in nations with flourishing public welfare markets. Regardless of whether the government selects them or how much value it assigns to each, the major charitable fundraising information platforms cannot avoid market competition and the scrutiny of the public.

In 2017, a bitter fundraising dispute rose up around the “Shenzhen Ai You Future Charitable Foundation,” a public campaign foundation and charitable organization registered with the Shenzhen Office of Civil Affairs. At the beginning of the year, Ai You raised RMB 15 million in just seven hours through its “One-Yuan Painting” donation drive. Ai You Future did not clarify the destination of these donations, leading many donors to believe their money was going to the autistic artists who made the paintings being sold, provoking controversy around the campaign.¹¹ Then on December 23, Ai You launched the “Decibel Counter One-to-One Financial Aid” campaign, a registered campaign on the Charity in China website. The campaign, called “Birthday Buddies,” raised money for poor children living in mountainous regions. Spreading quickly on WeChat users’ “Moments” feeds, the campaign quickly raised a substantial amount of money. At the same time, doubt arose that the campaign was fake and that the information being shared was incorrect. On December 25, the Shenzhen Office of Civil Affairs announced on its official Weibo account, “The Shenzhen Civil Affairs Bureau Office of Investigation has spoken with the secretary-general of the Shenzhen Ai You Future Foundation and has ordered the organization to immediately suspend the ‘Birthday Buddies’ online donation campaign. We have also asked the organization to submit a report on its fundraising activities and all documentation of partnership agreements with businesses, as well as all public announcements. The investigation is ongoing.” While the office of public affairs called for a halt to the campaign, the fundraising activity was also in danger of violating the Charity Law. The results of the investigation have not yet been released. In addition, the campaign used photos of the children receiving financial aid, posing a threat to the children’s privacy. In its public apology, “Birthday Buddies” sponsor Ai You Future affirmed that “the selection and supervision of our partner is of the utmost importance,” and furthermore that as the charitable organization, Ai You must shoulder most of the responsibility for ensuring that “all tools for executing our public welfare projects conform with regulations, fundraising is open and transparent, and fundraising is balanced with ethics.”

In the age of the Charity Law, donation drives run by unqualified charitable fundraisers are not treated lightly. In July 2017, the Public Security Bureau announced that the Shenzhen Shanxinhui Cultural Propagation LLC was under investigation for an alleged pyramid scheme, and that founder Zhang Tianming was suspected of using “poverty alleviation and wealth redistribution” as a cover for the fraud and was criminally detained. Soon after several Shanxinhui organizations nationwide were banned and a number of people arrested.¹²

Tightening the Screws on Management of CSOs

As early as 2013, with the release of the Guangzhou City Measure for Management of Civil Society Organizations (Draft Open for Comment), local CSOs started a discussion among several CSOs, scholars, and lawyers who worried that the government would be micro-managing CSOs.¹³ Nonetheless, strengthening management of CSOs became a trend. On August 21, 2016, the General Office of the C.C.P. Central Committee and the General Office of the State Council jointly issued the Reform Opinion, which states,

Governments at all levels and relevant departments will, according to their functions, work on the basis of a division of labor to strengthen management of social organizations’ internal governance, activities in their respective fields of operation, and overseas exchanges. Civil affairs departments will use methods such as inspections and evaluations to carry out oversight in accordance with the law over social organizations’ responsible persons, funds, activities, information transparency, their implementation of their charters, and so on; establish databases of “social organizations which present with suspect behavior” and “blacklists”; strengthen coordination and joint action with relevant departments, linking the genuine performance of social organizations with the tax exemptions they enjoy, the functions they take over in the transformation of government functions and their provision of government-purchased services. Civil affairs departments will work in conjunction with relevant departments to establish systems for joint administration of law, to strictly investigate and punish behavior in violation of laws and regulations, and to act in accordance with the law to close down all types of illegal social organizations that have not registered. Organizations that have been shut down but continue to operate illegally as social organizations, are to be dealt with by the public security organs in accordance with law.

In 2017, measures to tightly control CSOs are visible in four respects discussed below.

Every Locale Has a “Suspect List” System: Foreign Involvement That Is Not Documented, Without Established C.C.P. Organization May Be Added to Directory

In 2016 there were 2363 cases of CSOs across the country investigated and prosecuted for violation of the law and regulations. Since 2015, local civil affairs bureaus have formulated measures to manage CSO “suspect lists.” In October 2015 the Guangzhou Civil Affairs Bureau published its first directory of 68 municipal-level CSOs which presented with suspect behavior (known as the “suspect list”).¹⁴ The following March, these 68 organizations were inspected at random by the Ministry of Civil Affairs, ordering them to correct a number of issues: modification of registered programs, internal governance, regulatory systems, reporting of major programs, and carrying out of activities and finances.¹⁵ The Shenzhen Measure for Management of Civil Society Organization Directory of Suspicious Activity, issued in September 2016, distinguishes two directories: one for suspect activities, and another for permanently suspect activities. The Measure for Management of the CSO Loss-of-Faith “Suspect Directory,” issued by the Shenyang Civil Affairs Bureau in May 2017, stipulates that a CSO that engages in any one of 15 inappropriate actions will be placed on the activity “suspect directory.”¹⁶

When a CSO is added to the “suspect directory,” it impacts not only the organization’s partnership with the government, but also its other sources of funds. The Measure on Recognition of Charitable Organizations stipulates that four conditions will prevent an organization from being recognized as a charity, including “addition to the suspect directory by the Civil Affairs Bureau during the application process” and “administrative punishment within two years prior to the application process.” CSOs that are concerned about their ability to continue to develop are forced to ensure they do not “step on a mine” and get added to the list.

Guangzhou Civil Affairs Bureau’s “Directory of Suspicious Activity”

On May 15, 2017, the Guangzhou Civil Affairs Bureau made public its “suspect activities directory” via the city’s CSO information system, indicating that all local non-enterprise work units would be subject to city-wide inspections in 2017. Six CSOs, including the Qiaoyi Social Services Center, were found to have been “hiding the truth in their public statements and practicing fraud,” as described in Article 15 of the Guangzhou Measure on CSO Open Information. These six organizations were added to the “suspect activities directory.”

On May 23, one of these organizations issued a public statement explaining that a program involving a foreign partner mentioned in their annual report had not yet appeared in their official documentation of foreign involvement. The organization submitted an appeal within 30 days, in accordance with regulation, and was removed from the “suspect activities directory” on June 16.

On July 20, the Civil Affairs Bureau announced that 10 CSOs had fulfilled their duty to publicly release information (adding unreported years to their annual reports, meeting their obligation to publicly report information, and correcting public information) and would therefore be removed from the “suspect activities directory.”

On December 20, the Guangzhou Civil Affairs Bureau released the name of 58 organizations added in 2017 to the “suspect activities directory.”

On November 2017, the Ministry of Civil Affairs promulgated the Measure on the Management of Trustworthy CSO Information (Draft for Comment). The regulations stipulate that charities which have not yet set up Party organizations and which publicly fundraise in violation of any one of six rules listed in Article 21 of the Measure will be added to the suspect activities directory by its registration management body. Once the organization remains on the list for two full years, or violates any one of eight regulations, including those whose suspended activities receive administrative punishment, will be added to a list of seriously untrustworthy organizations. The Draft for Comment also states that CSOs with “good credit” and those on the untrustworthy list will be commended or punished accordingly.

Reinforced Strikes Against Unregistered CSOs

On August 30, 2016, the Ministry of Civil Affairs Civil Organization Management Administration announced that it was now to be known as the CSO Management Administration (CSO Law Enforcement and Supervision) and internationally as the State CSO Management Administration. Ministry of Civil Affairs Party Organization member and CSO Management Administration Director Zhan Chengfu states that the new office has a broadened remit to enforce the law and monitor CSOs, and that going forward it will have increased powers to hear cases of reported illegal CSOs, as well as to monitor and prosecute organizations carrying out activities that are not registered with the Ministry and organizations that continue to run activities after they have been banned.

Starting March 16, 2016, the Ministry of Civil Affairs released 13 lists of “offshore associations” and “fake associations,” a grand total of 1,200 organization.¹⁷ Yet by the end of 2016, only 16 illegal CSOs had been banned.¹⁸ China Social Organizations Online has created a “offshore association” and “fake association” public platform. A “fake association” is one that has not yet registered with a civil affairs bureau. Most are registered outside of China, and many hide behind the “national” label. They are often sheltered by a government office or a “lead advisor”¹⁹ with which they have a chain of benefit. While “fake associations” have been exposed by the Ministry of Civil Affairs, the media report that many such cultural organizations are still actively recruiting members and hosting meetings.²⁰

Since the FNGO Law took effect, CSOs that are not registered domestically are supposed to be punished and sanctioned by the Ministry of Public Security. Yet in 2017, most of the banning of illegal CSOs happened in Beijing and were executed by civil affairs, not public security. In September 2017, Beijing banned the “Chinese Research Center for Science and Technology Innovation & Strategic Development,” which had created 40 committees across 20 provinces and municipalities, including the Working Committee for Military-Civilian Integration and the Working Committee for County-Level Economic Development. In the city’s biggest crackdown on an illegal CSO, the Beijing Civil Affairs Bureau sent notice of the ban to many of the organizations under the “Research Institute” and confiscated illegal property.²¹ By September, the city had banned seven illegal CSOs and opened investigations into 10 organizations suspected of illegal activity. It also issued notices of investigation to the community.²² In November, the city civil affairs bureau initiated bans against organizations “connected to the military,” including the “Committee for the Chinese Veterans Welfare Fund” and its subordinate committees, institutes, and endowments. None of the above-mentioned organizations had registered with any government-affiliated work unit, bureau of industry, and commerce or civil affairs bureau. The Beijing Civil Affairs Bureau says it will continue to strike hard and ban any illegal CSO it finds.²³

Strict Registration Requirements for CSOs

As early as 2013, the State Council Plan to Reform Organizations and Change Functions had already put forward that professional associations and service organizations for science and technology, public welfare, charity, and urban and rural communities did not need the consent of an organization in charge of operations and could directly apply to a civil affairs bureau for registration. However, research shows that CSOs in Beijing and Guangzhou have had difficulty registering directly, while environmental CSOs have not been permitted to register directly at all.

The Yunnan Department of Civil Affairs announced that prior to the appearance of the General Offices of the Yunnan Party Committee & Yunnan People’s Government Effective Opinion on Reforming the CSO System and Promoting the Healthy and Orderly Development of CSOs (Yunnan Opinion 2017 No. 1), CSOs outside of the remit for direct registration would still fall under the system of registration management bodies and organizations in charge of operations. Before June 30, 2017, the provincial Department of Civil Affairs identified 184 CSOs that were already registered but did not fall within the scope of organizations permitted to register directly. Among them were 93 social organizations and 91 non-enterprise work units, which were given a limited time in which to contact an organization in charge of operations, apply for the transfer of their registration certificate, or else to apply for the revocation of their registration. The Yunnan Association for the Promotion of Women and Children, the Yunnan Society for Agricultural and Environmental Protection, the Yunnan Zexin Social Services Center, and other organizations that would appear to be qualified for direct registration were required to identify organizations in charge of operations.

Serious Punishment for Politically Sensitive CSOs: Space for Rights-Focused Organizations Continues to Shrink

Under the current system of CSO registration, groups focused on labor, LGBT, and human rights have a difficult time registering with civil affairs bureaus. These rights-focused groups are at a higher risk of being labelled as illegal and banned. If the organization’s leader is arrested, the group may not be able to continue operations. In September 2017, the director of Human Rights Campaign in China (HRCC), Zhen Jianghua, was detained in Zhuhai, Guangdong province on suspicion of “inciting subversion of the state.” To date, he has not seen his lawyer. HRCC was founded in 2008 by a group of volunteers monitoring human rights in China. In 2015, the organization registered in Hong Kong as the Human Rights Campaign Service Center. HRCC’s core mission is to defend everyone’s right to free speech, to empower all members of society to realize their rights, and to ensure these rights are fulfilled through supporting actions. There is little space for rights advocacy organizations to exist under the FNGO Law.

Disbanding “Politically Sensitive” Organizations

As soon as a legally registered organization is thought to be politically sensitive, even if it has not violated any of the regulations governing CSO management, the registration management body will pressure the organization’s administration to revoke its registration. In August 2017, the Yiqi Social Institute, based in Guangzhou’s Yuexiu District, announced that it had suspended an August 1 activity and was dissolving the organization. Yiqi was an NGO devoted to promoting the success of children and youth and to spreading social value. It is believed that a special guest invited to the launch of an activity was considered sensitive. Earlier, the organization was called in for meetings several times by the civil affairs bureau. When the board chair/founder was unable to reach an agreement, others in the organization, lead by board member Chen Xiaoyun, passed this resolution.

In July 2017, the Ministry of Civil Affairs announced that the Yinggongyi Foundation and the Zijin Mining Charitable Foundation would have their registration revoked and activities suspended for a month, respectively. Launched in Beijing in 2011 by the Communist Youth League Central Committee as a national non-fundraising organization to support the success of youth, Yinggongyi lost its registration for “disregarding regulation in accepting annual inspections in 2014 and 2015.” Rumor has it that the founder of Yinggongyi is Gu Liping, wife of former Politburo member Ling Jihua. A “man of interest” during the 18th Party Congress, Ling is currently serving a life sentence in prison. Zijin was ordered to suspend activities for a month for “carrying out activities not in accordance within its operational scope by subsidizing the Great Buddha project at Dongsheng Temple in Urad Back Banner, Inner Mongolia and the Golden Camellia Sculpture in the courtyard of the municipal business operations center in Longyan, Fujian Province.”

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1. According to the 2016 Statistical Communiqué on Social Services Development issued on August 3, 2017 by the Ministry of Civil Affairs, at the end of 2016 there were 702,000 CSOs throughout China, including 336,000 social organizations, 5559 foundations and 361,000 popular non-enterprise work units.↩
2. “China’s First Legislation on Foreign NGOs,” Caijing Magazine, May 25, 2015.↩
3. Fu Ying. “Over than 7000 Foreign NGOs in China.” China Youth Daily, March 4, 2016.↩
4. Report on Progress of Implementation of Law on Administration of Activities of Overseas Nongovernmental Organizations in the Mainland of China in its First Year.↩
5. Ye Ming, Analysis of Implementation of Law on Administration of Activities of Overseas Nongovernmental Organizations in the Mainland of China, Beijing Normal University China Philanthropy Research Institute, 2017.↩
6. Ibid.↩
7. “Charity Law Took Effect September 1; Here Are the Supporting Regulations,” China Philanthropy Times, September 4, 2016.↩
8. Zhong Xiaohui and Chen Anna, “Problems in China’s Charitable Fundraising Management System and Lessons from International Experience,” Lingnan Journal, 2017 Issue 2.↩
9. Na Diya, “Tsinghua Professor: Three Open Information Platforms Key to Launch of Charity Law,” Southern Metropolis Daily, October 10, 2017.↩
10. Charity in China Open Information Platform, October 31, 2017.↩
11. “‘Birthday Buddies’ Online Fundraiser Suspended, Shenzhen Civil Affairs Speaks with Ai You [Foundation] and Continues Investigation,” The Paper (Shanghai), December 25, 2017.↩
12. “National Civil Society Organization Management Administration Established, Illegal Organizations Will Be Banned,” Beijing News, August 30, 2016.↩
13. Zhao Xinxing, “Managing Civil Society Organizations Is ‘About Broad Strokes, Not Fine Points,’” Nanfang Daily, November 26, 2013.↩
14. Li Qiang and Yin Rui, “68 Civil Society Organizations on suspect list,” Nanfang Daily, October 13, 2015.↩
15. “Random Inspections of First Guangzhou Civil Society Organizations to Be Put on Suspect List,” Guangzhou Civil Society Open Information Platform,” March 24, 2016.↩
16. Zhu Qin, “15 Legitimate Activities Added to ‘Suspect List,’” Xinhua, May 11, 2017.↩
17. “Staunch the Impact of ‘Fake Associations,’ Get Back to Original Intent,” China Charity Federation Daily, December 11, 2017.↩
18. “In 2016, China Investigates and Prosecutes Over 2362 Civil Society Organizations in Violation of Laws and Regulations, Bans 16 Illegal Organizations,” Xinhua, August 3, 2017.↩
19. “What’s Behind the Resurgence of ‘Fake Associations,’” Xinhua, 2017.↩
20. “Ministry of Civil Affairs Names Fake Associations, Some on List Cry Foul,” Beijing Youth Daily, April 28, 2016.↩
21. “City of Beijing Bans Big Illegal Civil Society Organization,” Xinhua, September 19, 2017.↩
22. “Beijing Civil Affairs Bureau Bans 7 Illegal Civil Society Organizations,” People’s Daily Online, November 10, 2017.↩
23. “City of Beijing Complies with Law, Bans Several Illegal Civil Society Organizations ‘Involved with Military,’” China News Service, November 10, 2017.↩