Myanmar: Analysis of the Organisation Registration Law permission must still be obtained from the relevant local administration. To obtain permission, the organisation must provide information on the funds and goods to be donated and the activities that will be carried out.125 Organisations also must obtain special permission to work in travel restricted areas from the relevant local administration and from security forces.126 This provision merely encodes in the NGO Law a longstanding reality: military and civilian authorities have regularly imposed travel restrictions on conflict-affected regions of Myanmar, including severe restrictions on humanitarian aid, both before and after the coup.127 7.2. Assessment against International Standards Taken together, the restrictions on activities in the NGO Law are substantial, effectively foreclosing political advocacy, limiting engagement in political or economic matters, and imposing geographic limitations particularly in areas of conflict or national disaster. The requirement to obtain approval for changes, combined with the oversight described earlier, also mean that NGOs are likely to limit their activities to those considered to be acceptable by registration boards and other authorities. Excluding certain spheres of activities from those permitted to NGOs is inconsistent with international human rights standards. NGOs should have the right to “participate in public policy debates, including debates about and criticism of existing or proposed State policies or actions.”128 While it is legitimate to create separate regimes for the registration of political parties and religious organisations, and to prohibit entities registered as NGOs from acting as surrogates for those sorts of organisations, the prohibitions in the NGO Law go very far beyond that and limit the ability of NGOs to engage in anything deemed by military dominated bodies to represent political or religious activity. The right to freedom of expression, exercised in association with others, means that NGOs should be free to speak on all manner of topics. This freedom can only be restricted in a precise manner, in accordance with the three-part test under international law. A general requirement to engage only in “social activities” or to pursue only activities which are approved by a registration body, conflicts with the exercise of these rights. Overall, the NGO Law attempts to define a list of permissible and impermissible activities for NGOs, which is not a valid approach under international human rights law: 125 NGO Law, sections 27(h) and 28(k). NGO Law, section 28(m). 127 See, for example, International Crisis Group, Fire and Ice: Conflict and Drugs in Myanmar’s Shan State, 8 January 2019, https://www.crisisgroup.org/asia/south-east-asia/myanmar/299-fire-and-ice-conflict-and-drugs-myanmarsshan-state; and Development Media Group, Regime imposes travel restrictions on nongovernmental organisations in Arakan State, 18 July 2022, https://bit.ly/3IdsYsA. 128 2009 Report of the Special Rapporteur on human rights defenders, note 99, para. 122. 126 The Centre for Law and Democracy is a non-profit human rights organisation working internationally to provide legal expertise on foundational rights for democracy. 28