Myanmar: Analysis of the Organisation Registration Law
4. Registration and Renewal Procedures
4.1.
Requirements under the NGO Law
4.1.1. Domestic Organisations
Domestic organisations must register with the board which covers the geographic region in
which they wish to operate, so those operating nationally must register with the Union
Registration Board.59 The application for registration must include a range of information
listed in section 7 of the Law. This includes basic information such as the organisation’s name,
address, president and secretary, as well as the number of members and number of executive
committee members. While the Law does not require the citizenship of members to be listed,
local NGOs are supposed to have at least five Myanmar citizen members, so it may also be
necessary to provide this information.60
The application must also describe the organisation’s articles of association, objectives and
intended programme, a list of cash and assets and a commitment to comply with the law. It
must also list the “social activities” to be carried out. The NGO Law has a specific definition
of social activities, meaning non-profit activities for the common good which are not related
to the political, economic or religious sectors,61 suggesting that organisations will need to
show that their activities fall within the scope of this definition. The organisation must also
submit a recommendation from the government entity which covers their intended area of
activities (relevant sector body).
Once a registration board receives an application, it issues a temporary registration certificate
within 21 days. The NGO Law defines “registration certificate” to include a temporary one,
suggesting organisations with temporary certificates are equivalent to a registered
organisation, except for the uncertainty arising from a potentially indefinite wait for a final
certificate, 62 since no deadline is specified for the registration boards to make a final
decision.63
Before issuing a final certificate, the registration boards are supposed to scrutinise the
application according to prescribed rules.64 However, registration boards are supposed to
assign a government department to conduct pre-screening and to help the board come to a
59
NGO Law, section 12(b).
NGO Law, section 2(c).
61
NGO Law, section 2(g).
62
NGO Law, section 2(f). In accordance with section 51, however, organisations with temporary certificates are not
required to give their assets to a designated government department if their certificates are revoked.
63
NGO Law, section 8(d). Deadlines for providing certificates or notice of denial start from the time of the decision
to provide or deny registration, not when the application was submitted, a change from the 2014 Law, leaving no time
requirement for the decision itself.
64
NGO Law, section 8(b).
60
The Centre for Law and Democracy is a non-profit human rights organisation working
internationally to provide legal expertise on foundational rights for democracy.
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