We regularly update this list of questions with information drawn from Chinese law, official statements, and our interviews about NGOs’ on-the-ground experiences

What Is Considered a “Temporary Activity”?

There is no formal written Ministry of Public Security (MPS) definition of a temporary activity. This category appears largely to be a mechanism by which the MPS can remain apprised of foreign NGO activity in China, even if a Foreign NGO does not have a permanent presence in the mainland. However, Articles 3 and 5 of the Foreign NGO Law still apply to temporary activities.Read more

What Is Considered “Fundraising”?

The Ministry of Public Security has not offered clear guidance on this point. Notably, an earlier draft of the Foreign NGO Law forbade “accept[ing] donations from within Mainland China.” The final version of the Law says only that foreign NGOs and their representative offices may not fundraise within mainland China.Read more
According to the Foreign NGO Law, a foreign NGO must provide “proof of premises of the proposed representative office,” though the law is not explicit on what constitutes “proof” if an NGO does not yet have an established presence in China. This requirement may not present any problems for foreign NGOs that already had a presence in China and are now seeking to register under the new legal regime, but it may present difficulties for...Read more
The China NGO Project is not aware of any groups who have been explicitly denied registration by the Ministry of Public Security (MPS) or by a provincial Public Security Bureau (PSB). Similarly, we are not aware of any groups who have had their temporary activity filings explicitly rejected by a PSB or being forcibly shut down while in process.However, we assess that the Foreign NGO Law’s registration and filing system is such that outright rejections...Read more
The Ministry of Public Security (MPS) has not offered formal guidance on this point, though it is becoming more pressing for NGOs who have been unable to obtain sponsorship from unresponsive Professional Supervisory Units (PSUs). Several NGOs have told The China NGO Project that public security officials seem to appreciate the challenges for foreign NGOs seeking a PSU, and that the NGOs themselves feel reasonably secure as long as they are making a good-faith effort...Read more