Myanmar: Analysis of the Organisation Registration Law get permission to conduct activities from the local administration in the area where it proposes to do this. Beyond listing its social activities, as is required for domestic NGOs, international NGOs must list their sources of funding for these activities. Otherwise, both registration and renewal procedures for international NGOs are largely identical to those for national NGOs. Registration fees for both registration and renewal are higher, however, at MMK 500,000 and 300,000 respectively (approximately USD 235 and 140).74 As with national NGOs, many of these more burdensome requirements for international NGOs are new. Under the 2014 Law, international NGOs did not need a draft memorandum of understanding or all of the formal recommendations required under the new NGO Law, for example. An executive committee with Myanmar membership was also not required. 4.2. Assessment against International Standards Any procedure for organisations to obtain legal status, such as an NGO registration scheme, should be simple and accessible, with low or non-existent fees and short timelines for responding. “Burdensome, lengthy, arbitrary and expensive registration requirements” inappropriately limit the ability of organisations to exercise their right to freedom of association.75 The registration requirements under the NGO Law do not meet these standards. Some of the documents which must be submitted at registration are burdensome to obtain or are unnecessarily intrusive, such as describing intended activities or obtaining a recommendation from the relevant sector government department. Fees may be burdensome for small organisations, especially those registered at district and township levels where fees were not previously required. Timelines in the NGO Law do not ensure that registration will be “prompt and expeditious”, as required by international standards.76 NGO registration laws should set short deadlines to respond to applications.77 They should clarify the status of organisations while a decision is pending and enable organisations to begin operations in the interim.78 The NGO Law’s deadline for issuing a temporary certificate (21 days) is not very unreasonable but is still somewhat lengthy. However, the lack of any deadline for a decision on the final certificate is troubling. NGOs operating with a temporary certificate face the threat of a future decision denying registration, limiting opportunities for long-term planning 74 NGO Law, sections 19(a) and 22(d). 2009 Report of the Special Rapporteur on human rights defenders, note 34, para. 70. 76 Ibid., para. 110. 77 2012 Report of the Special Rapporteur on assembly and association, note 17, para. 60. 78 2009 Report of the Special Rapporteur on human rights defenders, note 34, para. 66. 75 The Centre for Law and Democracy is a non-profit human rights organisation working internationally to provide legal expertise on foundational rights for democracy. 16