On September 8, 2016 China's State Administration for Religious Affairs (SARA) sent a draft amendment for religious affairs administration to the Legal Office of the State Council. The amendments were posted online through the State Council website, requesting public opinions on the draft before October 7 of this year.
The draft amendments are extensive and call for, among other things:
- No religious activities outside of those approved by SARA
- No one should provide a venue to religious entities or activities not approved by SARA
- No personal residences or facilities should be used for religious activities not approved by SARA (basically eliminating family or home Bible studies)
- No one can go overseas for religious study without approval by SARA
- No one should publish any religious materials (through their own channels or through commercial publishers) without approval by SARA
- No donations (foreign or domestic) should be given to any religious entity or activity that has not been approved by SARA
- No one can hold the title of pastor or clergy without the approval of SARA
- No international religious exchanges can take place without the approval of SARA
- No Bible or theological schools and study can take place in China without the approval of SARA
As currently written, these amendments to the administration of religion in China by SARA would in effect leave no space for the house or unregistered church in China and would significantly curtail many of the activities of the TSPM as well.
Under the existing 2005 regulations, which were more ambiguous, the house church and other unofficial religious activities have been able to continue. The different and worrying aspects of the amendments now being proposed are the significant penalties attached to violations, along with a mechanism for enforcement.
According to some observers, SARA's strategy in proposing these amendments to the State Council Legal Office appears to be two-fold:
- To establish their own version of rule by law and present it as in keeping with President Xi Jinping's call for a "rule of law" in China as a means to validate the move, and then
- To make SARA the enforcer of that law.
The State Council is apparently neutral on the amendments, making this very much a SARA initiative.
The proposed amendments do not appear to be in keeping with the Chinese Constitution, Article 36, ensuring religious freedom as defined by China.
Furthermore, SARA's apparent attempt to go beyond its role as an administrator of central government policy suggests a desire to assume more power by taking on a policy making role.
If these measures were to be approved and implemented they have the potential impact of alienating China's sizeable Protestant Christian community, while also alienating millions of other religious believers in China.
For further information on the proposed regulations see: