INGOs in China’s Third Sector: Reframing Non-Profits between Adaptation and Compliance

Although International Non-Governmental Organisations (INGOs) have been operating in China since the late 1980s, it was not until the new INGO Law came into force in 2017 that INGOs’ activities were put under a formal regulatory framework for the first time. While the law filled a legal gap that had been left deliberately ambiguous for over 30 years, it also introduced significant constraints that reshaped the operational environment for INGOs in China. Adopting the perspective of INGOs seeking to establish and maintain a presence in China, this study examines the main regulatory, financial, and organisational challenges they face, and analyses how the new legal requirements affect their capacity to operate autonomously. The thesis employs a multi-layered methodology that combines formal social science theories with the analysis of primary and secondary sources in both English and Chinese. Drawing on the accountability framework, the study argues that the enactment of the INGO Law has prompted a shift in INGOs’ priorities from downward accountability through social service provision towards upward accountability through compliance with supervisory authorities. Additionally, the study develops an index to assess the degree to which INGOs operating in different sectors are institutionally welcomed in China. Ultimately, the findings suggest that the INGO Law has not only tightened regulatory oversight but has also structurally reoriented INGOs’ operational priorities, with significant implications for their long-term sustainability in China.