Overseas NGOs in China became increasingly active in 2024, creating new expectations for 2025.
I. Rising Number of Representative Office Registrations
According to data released by the Overseas NGO Management Office of the Ministry of Public Security, a growing number of Overseas NGOs have chosen to register representative offices in China. With the impact of the pandemic waning, the growth of NGO registrations has accelerated.
From these figures, it is evident that in 2024, the number of successfully registered representative offices was significantly higher than in 2022 and 2023 and included well-known NGOs such as ACCA, CPA Australia, and the American Heart Association. This reflects the high level of interest and active participation of Overseas NGOs in the Chinese market.
II. Sustained Positive Trends in Macro-policies for NGOs
Since the initial drafting stage of the Law of the People’s Republic of China on the Administration of Activities of Overseas Non-Governmental Organizations (hereinafter referred to as the “NGO Law”) and through 2024, the Chinese government has maintained a supportive attitude toward the development of Overseas NGOs in China.
In 2015, during the drafting stage of the NGO Law, President Xi Jinping stated, “China acknowledges the positive role of foreign non-profit organizations. As long as their activities benefit the Chinese people, we will not only refrain from limiting or prohibiting them, but also protect their operations through law, safeguarding their lawful rights and interests in China.” In October 2024, at an event marking the 70th anniversary of the Chinese People’s Association for Friendship with Foreign Countries, President Xi further emphasized “the unique role of people-to-people diplomacy” and the goal of “jointly building a community with a shared future for mankind.”
Local authorities have also introduced policies to support Overseas NGOs, conducting coordination and communication efforts to foster favorable operating environments. For instance, Shanghai’s Pudong New Area announced the “Provisions on Promoting the Development of International Economic Organizations,” which aims to create an international economic organization hub. The Beijing Municipal Public Security Bureau’s NGO Management Office held the “2024 Training Session for Representative Offices of Overseas NGOs in Beijing” to help Overseas NGOs better understand the relevant policies and regulations.
III. Balancing Security and Cooperation
A comprehensive analysis of China’s laws and regulations related to Overseas NGOs, as well as speeches by Chinese government leaders and statements from high-level meetings, reveals three recurring themes:
1.“Security.” China attaches great importance to safeguarding national sovereignty and social stability, while exercising strict supervision over potential “external interference” that may arise when Overseas NGOs carry out public-benefit activities. There have been some cases already of Overseas NGOs facing penalties for regulatory infractions.
2.“Cooperation.” China welcomes and encourages Overseas NGOs to bring in advanced concepts and resources to jointly promote social development, within the bounds of Chinese laws and regulations.
3.“Rule of Law.” All Overseas NGOs operating in China must comply with the NGO Law and related legal frameworks and adhere strictly to the financial and personnel management requirements.
IV. Recommendations for Reference
1. Obtain Information from Authoritative Sources
For more detailed insights into official interpretations by the Chinese government regarding Overseas NGO management, refer to:
- Publications or compilations of leaders’ speeches released by Qiushi Journal, Xinhua News Agency, China Central Television, and People’s Daily;
- Policy interpretations and summaries of leadership statements about Overseas NGOs available on the Ministry of Public Security’s official website;
- Bulletins and press conference records from the National People’s Congress and the State Council concerning social organizations and national security.
2. Stay informed on legal and implementation developments
The supervision, approval process, and areas of focus often manifest in more specific regulations and operational guidelines issued or updated by official departments such as the Ministry of Public Security, the Ministry of Foreign Affairs, and the Ministry of Civil Affairs. While leadership speeches provide overarching policy guidance, practical execution requires careful study of the latest directives from each department.
3. Seek Professional Advice
Overseas NGOs operating legally in China should maintain clear and regular communication with supervisory bodies and registration authorities and it is crucial to keep abreast of shifting regulatory trends. When major laws or policies are updated, it is advisable to consult with specialized law firms to obtain more practical compliance guidance.
In 2024, the development of Overseas NGOs in China gained positive momentum. We expect that in 2025, within a framework of security and cooperation, Overseas NGOs will bring even greater value to Chinese society, by collaborating to advance high-quality development, optimize foreign-related business environments and together forge a brighter future.
For further information, please contact:
SUN, Jiangang (Roy), Partner, JunHe
sunjg@junhe.com
