Public security officials did not register any new foreign NGO representative offices in the month of May, marking the first time since the the Foreign NGO Law first took effect in January 2017 that an entire month elapsed without any registrations. During the height of the COVID-19 outbreak in China, authorities were still reporting new registrations, with three new offices registered in January, three in February, and five in March. The current lack of registrations may be due to the outbreak spreading globally, shuttering non-profit offices worldwide and slowing any registration applications in process.
Even before the COVID outbreak, however, the pace of new foreign NGO office registrations in China had been gradually slowing. 2017 saw an average of nearly 25 new representative office registered per month; in 2018, that dropped to 11 per month; in 2019, the figure hovered just under seven. So far in 2020, the average number of registrations per month is 3.6.
The China NGO Project assesses that this slowdown is, in part, simply a result of the law’s intended gatekeeper function: most of the foreign NGOs wishing to legally open a permanent office in China have attempted to do so, and have either successfully hung out their shingles or been silently rebuffed.
Another subset of foreign NGOs have also determined that opening a representative office is not feasible for them, preferring to work through the temporary activity mechanism or just leaving China altogether. Though additional international non-profits will no doubt become interested in working in China in the future, many of those with prior experience in doing so have already decided how they want to interact with the Foreign NGO Law, and these choices—along with those of public security authorities—are reflected in the more or less stable set of foreign NGOs we see registered in China today.