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May 17, 2019

Can My NGO Carry out Projects in More Than One Province or Location?

Can my organization carry out projects in more than one province or location, or are activities restricted to the area where the organization or activity is registered? Where does my organization register if we have operations in more than one city or province of China?

Per information provided at a meeting between Ministry of Public Security (MPS) representatives and foreign diplomats in 2016, a foreign NGO’s representative office may have activities in multiple locations as long as the geographic scope of its work is consistent with the information it provided in its registration documents.

If an NGO has multiple representative offices, the area of operations for these offices should not overlap; one office may not carry out activities in the registered jurisdiction of the other office.

This has been borne out by registration data provided on the MPS website. There are numerous foreign NGO representative offices that have been approved to operate in multiple provinces (or throughout all of China) but have only one registered representative office. This is also the case for a number of temporary activities that have been approved to work in multiple provinces per activity. A regularly updated suite of graphics showing the permitted area of operations for representative offices and temporary activities is available here.

At a talk for foreign NGOs in Beijing in November 2018, a Beijing Public Security Bureau (PSB) Foreign NGO Management Office official stated that foreign NGOs that have already registered a representative office cannot file for temporary activities, suggesting that any work undertaken by these NGOs must be within the geographic scope outlined in their registration documentation.

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