Where Are Representative Offices Actually Allowed to Work?

This article originally appeared on ChinaFile’s The China NGO Project.

Since mid-2017, The China NGO Project has mapped the location of registered foreign NGO representative offices in China (as listed on the Ministry of Public Security website). Not surprisingly, the majority of offices are located in either Beijing or Shanghai. These maps, however, only show the provinces where each office is located—they do not show where each office is permitted to operate, which can (but does not have to) extend beyond the province of registration. Using registration information through the end of November, The China NGO Project has now put this information into map and chart form, allowing for an easy comparison with the distribution of representative office locations:

These visualizations clearly show that while the distribution of actual offices is quite lopsided, the areas where foreign NGO representative offices are allowed to work are far more evenly distributed. From January 2017 through November 2018, the mean number of representative offices registered in any given province was 13.5 and the median number of offices per province was just five. Compare that with the distribution of permitted areas of operation, where the mean number of offices permitted to work in a given province was just over 58.9, while the median was 57. Means and medians that are close together indicate that there are not a few wild outliers drastically changing the mean. In the case of representative office registrations, Beijing and, to a lesser extent, Shanghai have vastly more registrations than all other provinces, resulting in an overall mean that is more than twice the median. Even if a given province has no or very few foreign NGO representative offices registered, that does not mean there are not foreign NGO offices carrying out work in that province.

Note that these maps do not include registered offices permitted to work throughout all of China. We did this for two reasons. First, including them would add the same number of additional offices to each province’s total, cancelling each other out. Second, if the goal of the visualization is to get a sense of where representative offices are conducting their work, it is difficult to know how many groups who are permitted to work in “all of China” (often written as “中国境内 (within China’s borders)” in the Ministry of Public Security database) actually exercise their option to carry out programs in, say, Xinjiang Bingtuan. Conversely, if a foreign NGO has applied to work in only a subset of provinces, it is more likely that they have specific programming that they plan to do there. In order to give readers a sense of how many representative offices are permitted to work in “all of China,” however, the bar charts do include these registrations as a separate entry.

Foreign NGOs’ permitted areas of operation are even more distributed than the locations of temporary activities. This is not a direct apples-to-apples comparison, however. In the case of temporary activities, filing information is generally place-specific and is tied to a discrete event with particular dates and times. In the case of representative offices, we do not have a reliable way of knowing how often any given registered NGO is actually working in any given province; for example, an NGO may have permission to work in four provinces but has so far only worked in two of those provinces.