Myanmar: Analysis of the Organisation Registration Law The precise renewal procedure is not articulated in the NGO Law, which merely says that the organisation shall apply “according to the prescribed rules”. However, the NGO Law does specify that the registration board should scrutinise the application in accordance with section 8(c), the provision permitting registration if doing so would not impact State sovereignty, security, the rule of law or national unity. 71 The assigned government department is also supposed to play a screening role during renewal.72 Once the renewal certificate is issued, the organisation must again pay a fee, ranging from MMK 10,000-100,000 (approximately USD 5-50). Failure to collect the certificate or provide proof of payment results in revocation of the decision to register. If the renewal is denied, a similar process applies as for initial applications, pursuant to which the organisation has 30 days to amend the application, after which the board makes a second and final decision. The basic registration procedure under the NGO Law is similar to that under the 2014 Law, but its requirements substantially complicate the process. For example, under the 2014 Law there was no requirement to obtain a recommendation from the relevant sector government department. There were also clearer and shorter deadlines, a second decision to deny registration was not final, and registration fees were either lower or non-existent for those registering with more local boards. For domestic NGOs, renewal was guaranteed if annual reports had been submitted and there was no registration fee. 4.1.2. International Organisations International organisations must register with the Union Registration Board. It seems likely that this would require them to establish some kind of Myanmar-focused entity, because they must have an executive committee with at least 40 percent Myanmar citizens and provide the name and contact information for the head of a Myanmar office (and any branch offices).73 They must also submit a range of other information about their international organisation and structure, such as its articles of incorporation and proof of recognition in the country in which it is legally established. Other information to be included in the application, which is detailed in section 17, could create some notable administrative hurdles for international NGOs. The application must include a draft Memorandum of Understanding, although with whom is not specified, which presumably must be negotiated prior to the application being made. As with national NGOs, international NGOs must obtain a recommendation from the relevant sector government department, but recommendations are also required from the Ministry of Investment and Foreign Economic Relations, and the Ministry of Immigration and Population, as is a letter asking for the opinion of the Ministry of Foreign Affairs. The international NGO must also 71 NGO Law, section 14(d). NGO Law, section 44. 73 NGO Law, sections 2(d) and 17(k). 72 The Centre for Law and Democracy is a non-profit human rights organisation working internationally to provide legal expertise on foundational rights for democracy. 15