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China’s Foreign NGO Law

A Silver Lining?


In a recent Christianity Today article on the wave of laws hitting foreign NGOs globally, Morgan Lee refers specifically to China when she writes, “Nearly 20 percent of the world’s population could lose access to the ministry efforts of Western Christians next year.”

Such a sweeping assertion may appear at first glance to severely overstate the impact of China’s new foreign NGO law, which takes effect next January. Nevertheless, depending on how the law is actually applied, its far-reaching provisions do have the potential to severely disrupt the “business as usual” that many foreign faith-based organizations have become accustomed to in China.

Foreign funding, which can take many forms, is of particular concern. Even if an organization is not actually based in China, if it is supporting local Christians to carry out activities in country then these activities are potentially covered by the new law. In order to be legal, funding for humanitarian work would need to be channeled through an officially recognized local-partner organization and subject to oversight by government regulatory agencies.

Overtly religious activities by foreign NGOs, on the other hand, are specifically forbidden. The law gives China’s public security organs broad powers to intervene in such cases, including seizing financial assets. More importantly, local Christians who knowingly receive foreign funding for illegal activities are subject to prosecution. 

By directly addressing the question of funding, the new foreign NGO law shines a light on an area that is timely not only from a legal perspective, but also, more importantly, in terms of the long-term development of China’s church.

Over the past nearly four decades of partnership with the church outside China, the indigenous church has become increasingly self sufficient in areas such as training, the provision of materials, and supporting its own workers. Still there remains a host of activities that are supported with overseas dollars, particularly where foreign and local Christians are working together or where programs originating from outside China are implemented locally. In some quarters there also remains the assumption that, if the work involves foreigners, then the funding will come from abroad.

While all involved would be quick to acknowledge the validity of the “three self” principles, in actuality the question of how to fund ministry remains a difficult and delicate questions.

Enter the new foreign NGO law, which brings a new sense of urgency to this discussion. If existing funding relationships are indeed at risk, then it is imperative that local believers and their foreign partners work together to explore new options for the long-term sustainability of their work. If the result is a stronger indigenous church and more healthy partnerships, then what may appear today as a looming threat may ultimately prove a great blessing to China’s Christians.

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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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