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 or work stoppages would only occur in extreme circumstances. In most cases, foreign NGOs could be unable to register an office or carry out a temporary activity without explicit PSB involvement. For example, when filing for a temporary activity, a foreign NGO’s Chinese Partner Unit may find itself unable to get the requisite approvals from its own supervisory entity, meaning it would never reach the stage where it sends its filing documentation to the PSB nor actually carries out the temporary activity. Similarly, a foreign NGO may not be able to secure the sponsorship of a Professional Supervisory Unit, meaning that it would never submit its registration materials to the PSB and then be denied permission to register. This does not mean that the PSB does not necessarily play a role in a Partner Unit or Supervisory Unit’s decision-making, only that cases of direct rejection from the PSB is likely to be rare given the design of the Foreign NGO Law’s registration and filing system.
According to a Beijing PSB Foreign NGO Management Office official at a talk for foreign NGOs in Beijing in November 2018, the authorities have not yet stopped any temporary activities already underway: “Until now, we haven’t found any activities not in accordance with this regulation. If we did find one, we would resolutely stop the activities, and carry out the relevant legal process towards the Chinese cooperation organization.”
If your organization has been explicitly denied registration or had a temporary activity shut down, please contact us to share your experience. We will not use your information on the site without your permission.