Myanmar: Analysis of the Organisation Registration Law Once registered, NGOs must submit a report on their activities once every three months to the relevant township GAD administrator. 103 No details are given on what should be included in these reports. The requirement would seemingly oblige even international NGOs and NGOs operating nationally to submit their reports at the township level, possibly in all of the 330 Myanmar townships in which they operate, but it is not clear what constitutes a “relevant” township.104 Registered organisations must also submit an annual financial report. For those registered with the national, regional/state or Naypyitaw boards, this report must be reviewed by a certified accountant; more local NGOs only need to have an accountant or audit panel of the executive committee review the report. Copies of this report must be sent to the relevant sector government entity which recommended that the NGO be registered.105 Beyond regular reporting requirements, the NGO Law provides for other ongoing oversight of registered organisations. Registration boards are supposed to assign a “relevant department” which, beyond screening an NGO at registration and renewal, also reviews any complaints about the organisation. 106 As noted in the registration section, it is not clear whether this is meant to be GAD, the recommending relevant sector government department or another entity. If the assigned government department deems a complaint to be justified, it reports to the registration board, which can then take an administration action or action according to another law. If it finds the complaint not to be justified, it keeps a record of the complaint and reports back to the registration board.107 The government entity which issued the recommendation letter or signed the memorandum of understanding, which as noted may be the same government entity but this is not entirely clear, is also supposed to report to the relevant registration board if it finds that the NGO is not complying with the rules. 108 This triggers a process whereby the registration board reviews the activities of the NGO and determines whether an administrative action is appropriate. The registration board also coordinates with relevant government departments if the actions of the NGO warrant an action under another law.109 Neither of these review processes are delineated very clearly in the NGO Law and indeed it is not even clear whether or not they represent two distinct processes. Ultimately, the NGO Law seems to envision oversight responsibility being vested in the registration board, the relevant sector government entity and also (possibly) GAD or another assigned department. 103 NGO Law, section 28(l). Myanmar Information Management Unit, MIMU Township Profiles, https://bit.ly/3IaorqW. 105 NGO Law, section 28(g). 106 NGO Law, section 44. 107 NGO Law, sections 44-45. 108 NGO Law, section 50. 109 NGO Law, section 32. 104 The Centre for Law and Democracy is a non-profit human rights organisation working internationally to provide legal expertise on foundational rights for democracy. 24