Myanmar: Analysis of the Organisation Registration Law
Introduction1
On 28 October 2022, Myanmar’s State Administration Council (SAC), a military creation
acting as a governing body since the February 2021 coup in Myanmar, issued a new
Organisation Registration Law (NGO Law). 2 The NGO Law imposes registration
requirements and otherwise regulates non-governmental organisations (NGOs) operating in
Myanmar. While some rumours of a new NGO law preceded this announcement, the NGO
Law was enacted without any apparent discussion or consultation with civil society.
The NGO Law, which came into effect in late December 2022, will have a serious harmful
impact on civil society in Myanmar, which has already suffered sustained attacks since the
2021 coup. As described in this Analysis, it renders the work of many NGOs unlawful unless
they comply with burdensome registration and monitoring requirements, and introduces the
threat of administrative and criminal sanctions for non-compliance.
The new restrictions will impact all sectors of civil society, with potentially deadly
consequences. Humanitarian needs in Myanmar today are acute. Half of the population is
living in poverty and almost one out of three people is expected to need humanitarian
assistance in 2023. Another 1.4 million people are forecast to become internally displaced in
2023, more than the 1.3 million existing displaced persons.3 Many crucial State services are
not operating – the public health system is in “near total collapse” – meaning that civil society
is providing vital support.4
The NGO Law will also engender additional harassment of any organisations deemed to be
politically active, critical of the military or supportive of opposition movements. It may result
in greater restrictions on ethnic civil society groups or those operating in regions with active
armed conflict. The NGO Law represents a further closing of space for non-violent political
opposition and debate in Myanmar, limiting avenues for peaceful expressions of opposition.
1
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2
State Administration Council Law No. 46/2022. This Analysis relies on the translation published in segments in the
Global New Light of Myanmar from 29 October 2022 to 5 November 2022 (GNLM Translation). CLD has
consolidated this translation into a single document available at: https://www.law-democracy.org/live/wpcontent/uploads/2023/06/Myanmar-Organization-Registration-Law-consolidated-English-version.pdf. Because this
translation appears to contain several errors or hard-to-understand phrases, CLD has also referred to an alternate
translation available at https://bit.ly/3jJIJy3 (Lincoln Translation). Discrepancies in the translations are noted in
footnotes throughout this Analysis.
3
UN Office for the Coordination of Humanitarian Affairs, p. 92, https://reliefweb.int/attachments/f0cc9858-071b4583-bcfe-e2dc2c288f7b/mmr_humanitarian_needs_overview_2023%20final.pdf;
Reliefweb,
“Myanmar
Humanitarian Update No. 26”, 2 February 2023, https://reliefweb.int/report/myanmar/myanmar-humanitarian-updateno-26-2-february-2023.
4
Ibid., p. 22.
The Centre for Law and Democracy is a non-profit human rights organisation working
internationally to provide legal expertise on foundational rights for democracy.
1