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The Overseas NGO Law: A Second Look

Following a rather chaotic start, the process of registering foreign entities under the Overseas NGO (ONGO) Law is getting underway, albeit slowly.

The Ministry of Public Security, charged with overseeing foreign organizations in China, is adapting to its new role. Organizations designated as Professional Supervisory Units (PSUs) are likewise forging partnerships with overseas groups. In some localities, provincial officials are taking the initiative to meet with overseas NGO representatives to help with registration.

As with any official initiative in China, implementation varies greatly from place to place. Some would-be applicants are finding it impossible to find a willing PSU. Others are discovering their local security officials are still in the process of understanding their new role and are thus not in a position to be helpful.

The fact that more than a dozen organizations with strong Christian identities have been approved for registration or for temporary activities is encouraging. Being known as “faith-based” is not necessarily a deal breaker when it comes to gaining legal recognition. Organizations that had early on dismissed the new law as simply a way of making it difficult for foreigners to operate in China would do well to take a second look. While not an easy task, given the amount of paperwork and permissions involved, formal NGO registration may nonetheless still be a viable option.

A growing body of online resources in Chinese and English exists to guide those seeking to understand the registration process. Meanwhile, the experience of scores of organizations that have successfully registered is helping to elucidate what had been a very opaque process.

For those foreign faith-based organizations for which registration is not an option, there are steps that can be taken to mitigate risk. Hundreds if not thousands of overseas faith-based groups are currently engaged in a wide variety of activities, both short- and long-term, that would technically not be covered by the ONGO Law. By repositioning their presence in China, such organizations can increase the likelihood that they will be able to remain meaningfully engaged in China in the current legal climate.

The team at ChinaSource is committed to staying as apprised as possible on the implementation of the Overseas NGO Law as it rolls out across the nation. This article is adapted from the latest installment of ChinaSource Law and Policy Monitor, which is being made available as part of an individualized consulting package for faith-based organizations engaged in China. For further information on how ChinaSource can serve you and your organization, please write to

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Image credit: Shanghai, China by Lei Han via Flickr.

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Brent Fulton

Brent Fulton

Brent Fulton is the founder of ChinaSource. Dr. Fulton served as the first president of ChinaSource until 2019. Prior to his service with ChinaSource, he served from 1995 to 2000 as the managing director of the Institute for Chinese Studies at Wheaton College. From 1987 to 1995 he served as founding …View Full Bio

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