Myanmar: Analysis of the Organisation Registration Law such as in relation to property matters, tax collection and birth registration.40 In recent years, GAD has increasingly played a role in local development projects and in coordinating with international donors, as well as the voluntary NGO registration system under the 2014 NGO Law.41 GAD also has strong military links and has long performed security, public order and intelligence-gathering functions. Historically, it provided a vehicle for local level military control and surveillance.42 The military maintained a strong degree of control over GAD even under civilian government, with senior leadership and a substantial number of staff having military ties. 43 Although, prior to the coup, GAD had been somewhat decentralised and integrated with subnational governments, efforts to reduce military influence and convert GAD into a democratically-accountable institution were still in their infancy.44 Since the coup, military control of GAD has again been re-entrenched. Just over a year before the coup, the government had attempted to transform GAD into a civilian-led department by relocating it from its long-standing home within MOHA. 45 Following the coup, the junta reversed this change and returned GAD to the control of the military-run MOHA. 46 The military has taken other steps to ensure loyalty within GAD, such as by installing pro-military allies in local positions, stoking old fears about GAD staff serving as informers.47 The role of MOHA and GAD in NGO regulation is not new, as both played similar roles under the 2014 Law, but the military’s control over both entities since the coup creates a substantially different environment. GAD’s role is also substantially enhanced, such as via new inspection powers. GAD now has the power to issue notifications, orders, directives and procedures under the NGO Law, and plays a much more powerful role in the NGO registration boards, as discussed in the following section. 40 Richard Batcheler, et al., State and Region Governments in Myanmar, October 2018, Asia Foundation, p. 58, https://bit.ly/3RLK9oq. See also Lachlan McDonald, “Making the Most of GAD Reforms”, 11 June 2020, Frontier, https://bit.ly/3RJLyeR. 41 Kyi Pyar Chit Saw and Matthew Arnold, Administering the State in Myanmar, Policy Dialogue Brief Series No. 6, March 2015, The Asia Foundation, p. 9, https://bit.ly/3DSB1Z8; and Batcheler, et al., note 40, p. 119 and annex k. 42 Frontier, “Communities Defy Junta’s Attempts to Rule Wards and Villages”, 14 May 2021, https://bit.ly/3DRSukF; Kyi Pyar Chit Saw and Matthew Arnold, note 41, p. 2; and Human Rights Watch, “Burma’s Military Milestone”, 30 March 2015, https://bit.ly/40BjiPH. 43 In 2020, a source indicated that “almost all” senior leadership, a majority of gazetted positions and 30 percent of all staff had military ties. Lachlan McDonald, note 40. 44 Batcheler, et al., note 40, p. 63. See also Nan Lwin, “Powerful and Expansive – Infographic Explainer of the General Administration Department”, 28 December 2018, The Irrawaddy, https://bit.ly/3RF4oE5. 45 Matthew B. Arnold, “Why GAD Reform Matters to Myanmar”, 24 August 2019, East Asia Forum, https://bit.ly/3HJ23mX. 46 State Administration Council Order No. 119/2021, 5 May 2021, https://bit.ly/3JM3xzz. 47 This has most notably occurred through replacing the previously elected ward and village administrators, but appointments of military supporters are likely occurring at higher levels as well. Han Thit, “Myanmar Junta Replaces Yangon Administrators with Hardline Supporters”, 21 December 2022, Myanmar Now, https://bit.ly/3YwlN47; and Frontier, “Communities Defy Junta’s Attempts to Rule Wards and Villages”, 14 April 2021, https://bit.ly/3HMAxFn. The Centre for Law and Democracy is a non-profit human rights organisation working internationally to provide legal expertise on foundational rights for democracy. 9