Welcome to The China NGO Project

On January 1, China began enforcement of its Law on the Management of Foreign Non-Governmental Organizations’ Activities in the People’s Republic of China. Several weeks later, we initiated The China NGO Project to try to help readers better understand the effects of this law and how it is being implemented on the ground. We’ve organized The China NGO Project website to address this subject from a number of different angles. We’ve compiled relevant laws, regulations, forms, and guides (and their English translations) in the Laws & Regulations section; we’ve assembled a set of online resources and reading materials in the Resources and Links sections; we’ve collected a list of basic questions from NGO staff and then provided preliminary answers to them in our FAQ section; and we’ve begun to evaluate what we’re seeing and hearing in our Analysis section.

Can My NGO Give Money to Individuals in China?

Based on the text of the Foreign NGO Law, it does not appear that foreign NGOs can lawfully give grants directly to individuals, such as for travel to workshops outside China, without a Chinese Partner as an intermediary. Article 22 states that individuals may not receive or spend any project funds that were not delivered through a Chinese Partner’s bank account. According to the NGOs in China Blog’s summary of guidance provided by the Ministry of Public Security at a 2016 Q&A session, individuals cannot be official Chinese Partners.

How Does the Law Apply to Non-Profit Performing Arts or Other Cultural Groups?

According to the NGOs in China blog’s summary of guidance provided by the Ministry of Public Security at a 2016 Q&A session, “Article 21 [of the law] permits foreign NGOs to use ‘other funds legally acquired within China’ for their activities in China. This means income or revenue is allowed as long as the foreign NGO keeps its not-for-profit nature, namely, will not distribute dividends or profit to its shareholders [or] owners.”

What Is a Professional Supervisory Unit’s Role in Terms of Oversight and Management?

A PSU’s precise role vis-a-vis its sponsored foreign NGO remains unclear at this stage in implementation. Many foreign NGOs report uncertainty about the nature of the relationship and have expressed a desire for greater clarity about the parameters of PSU management, but there is, as yet, no official Ministry of Public Security guidance nor enough real-world experience to determine how PSUs on the whole interact with their sponsored foreign NGOs.

What Documents Does My NGO Need To Report a Temporary Activity?

The following documentation must be filed with the relevant Public Security office at least 15 days before a temporary activity begins (note: this time restriction is waived in cases of emergency relief services): 1. Documents and materials showing the foreign NGO’s legal establishment; 2. A written agreement between the Foreign NGO and a Chinese Partner Unit; 3. Information about the temporary activity, including the activity’s name, objectives, region, and proposed timing and duration; 4. Materials showing the project budget, funding sources, and the bank account information of the Chinese Partner Unit; 5. Approval documents obtained by the Chinese Partner Unit; 6. Other documents and materials as required by law or administrative regulations.