Ten Years After the Charity Law: Whither Chinese NGOs?

Since the promulgation of the Charity Law of the People’s Republic of China in 2016, the relationship between the state and nongovernmental organisations (NGOs) in China has undergone profound changes. Drawing on fieldwork and an analysis of official policies and regulations, this essay argues that the positive term ‘charity’ has been strategically deployed by the state to establish discursive hegemony in the public sphere. This discursive dominance, combined with the Party-State’s strong and subtle coercive capabilities, has ensured the state’s firm control over agenda-setting and compelled the NGO sector to transition into one that primarily serves the state’s broader policy initiatives.

In March 2016, China’s National People’s Congress passed the Charity Law, the first official legal document specifically regulating philanthropic activities in the country. The law defines philanthropic activities as voluntary actions intended to benefit unspecified recipients in the public interest. The Charity Law designates 5 September each year as ‘China Charity Day’ and establishes regulatory provisions governing fundraising, donations, trusts, and service activities conducted for charitable purposes. Nongovernmental organisations (NGOs) engaged in philanthropic activities may apply to be accredited as charitable organisations, thereby legally enjoying the rights and privileges granted to such entities. At the time, some Chinese scholars and philanthropists viewed the passage of the law positively, celebrating it as a product of long-term efforts. They argued that it provided institutional support for NGOs engaging in philanthropic activities and would facilitate NGO development in China (Jin 2016; Spires 2020: 572).

Ten years on, according to the available statistics, the number of registered charitable organisations in China has exceeded 15,000, accounting for less than 2 per cent of all registered NGOs (Wang 2026). Annual social donations have not increased significantly over this period; in fact, the total amount of donations in 2024, the most recent year for which figures are available, was lower than in 2016 (Shu 2026; Wang 2017). Meanwhile, the number of registered NGOs declined for the third consecutive year between 2022 and 2024 (NBS 2025). These figures suggest that the law’s role in promoting philanthropy has been modest. However, the significance of the law cannot be assessed solely by these indicators. From a broader perspective on state–society relations under an authoritarian regime, I argue that the passage of the Charity Law reflects the state’s effort to construct a ‘charity’-centred discursive framework and strengthen its influence in the public sphere.

While the Party-State’s firm grip on civil society has long rested on its formidable coercive capacities, it has increasingly sought to complement regulatory control with ideological legitimacy. By emphasising NGOs’ roles as providers of social services and their alignment with the Party-State’s policy priorities, the charity-centred framework reinforces the Party-State’s preferred understanding of the NGO sector and its place within the existing political order. Backed by the state’s coercive capacities, this framework has contributed to the marginalisation of the civil society discourse that gained influence among grassroots NGOs in China during the reform era. In so doing, the Party-State seeks to establish what I term a form of discursive hegemony, whereby the state can define the dominant meanings, norms, and boundaries of legitimate civic participation.

Establishing an Alternative Discourse

NGOs in China can be roughly divided into two categories (Ma 2013). The first are government-organised NGOs (GONGOs). These organisations maintain close relationships with government agencies and align their activities with state policy priorities. The second category comprises grassroots NGOs, which emerge from bottom-up societal initiatives. Compared with GONGOs, grassroots NGOs enjoy greater autonomy and can determine their own agendas and strategies. In the eyes of the state, however, these organisations can be less predictable and thus a potential source of social instability. The regulatory system in China is primarily restrictive, which has created operational difficulties for grassroots NGOs. Nonetheless, these organisations have gained social recognition through service provision for vulnerable populations and advocacy on social issues. It is primarily this second category of grassroots NGOs that the charity framework was designed to contain.

Chinese grassroots NGOs have been significantly influenced by their Western counterparts. Western NGOs have provided them with not only financial support but also training in organisational and operational strategies. Through these connections, grassroots NGOs have internalised a civil society framework that conceptualises NGOs as a ‘third sector’ independent of both the state and the market. Within this framework, citizens organise themselves voluntarily to participate in public affairs and promote human rights and social justice in the face of a strong state. In this sense, the state is viewed as an entity that can be challenged. Although most grassroots NGOs in China do not position themselves as political opposition forces or explicitly advocate democratic reform, their active engagement in public affairs and their willingness to speak on social issues have often pressed the government to respond. In these processes, grassroots NGOs have demonstrated agenda-setting and mobilisational capacities that generate concern for the regime. While the Party-State possesses the capacity to directly intervene in NGO-led mobilisation, it has long struggled to counter NGOs’ narratives shaped by civil society theory. For the Chinese Communist Party, an independent NGO sector with its own normative commitments and the capacity to pressure the government into compromise poses a potential threat to regime durability. The party therefore requires an alternative discourse that emphasises NGOs’ role in serving one-party rule.

Confronted with this normative challenge, the party under President Xi Jinping sought to construct an alternative discursive framework to combat the Western-led civil society one that could not be suppressed by force alone. In 2013, the year after Xi assumed power, the internally circulated Document No. 9 identified civil society as one of seven ‘perilous Western values’ that must be resisted (ChinaFile Editors 2013). The passage of the Charity Law in 2016 became the primary instrument for precisely this purpose and two features of ‘charity’ as a concept made it particularly well-suited for the task.

First, the term ‘charity’ (慈善 cishan) is easily understood in the Chinese linguistic context and can be simply interpreted as ‘helping people in need’. The practice of wealthy local elites providing material support to the poor has long been embedded in Chinese history. Moreover, charity is compatible with broader socialist ideals that emphasise equality. At the Fourth Plenum of the Nineteenth Central Committee in 2019, the party further incorporated ‘charity’ into its official discourse. It introduced the concept of the ‘third distribution’ as part of its strategy to achieve ‘common prosperity’, encouraging social actors to reduce inequality by participating in charitable donations and service provision (Liu 2019).

Second, ‘charity’ is a depoliticised concept that the party can promote with little political risk. Even before the enactment of the Charity Law, the State Council had issued several guiding policy documents aimed at promoting societal engagement in philanthropic activities. These documents called on local governments to encourage NGOs to assist vulnerable groups, complementing the government’s social safety net. From the government’s perspective, encouraging NGOs to engage in nonpolitical activities diverts attention from critical inquiries into structural inequality and injustice within the political system.

Following the passage of the Charity Law, the state moved quickly to institutionalise this charity-centred discursive framework. Legislative and executive authorities subsequently issued or revised a series of laws and directives that provide more detailed rules on a wide range of operational issues for NGOs, including fundraising, information disclosure, and tax incentives. These measures further consolidated the institutional foundations of the charity discourse, enabling it to move beyond a state-promoted slogan and become a more practicable framework backed by formal institutions.

The cumulative effect of this charity-focused discourse is that the state asserts its leading role and incorporates NGOs into its broader framework of social governance. Major policy initiatives promoted by the state in recent years—including poverty alleviation, rural revitalisation, and improvements in elder care and community services—have been accompanied by official documents that delineate roles for NGOs. These documents also increasingly emphasise NGOs’ obligation to align with and serve national strategies. At the outset of the Fourteenth Five-Year Plan period (2021–25), the Ministry of Civil Affairs issued the first five-year plan specifically for NGO development. This document employed phrases such as ‘promoting social organisations to serve the overall national agenda [服务大局]’, encouraging NGOs to support national development initiatives (MOCA 2021). Likewise, a 2022 government document encouraging NGO participation in rural revitalisation stressed that ‘participation in rural revitalisation is both the responsibility of social organisations and an important manifestation of their service to the nation’ (MOCA and NRRA 2022).

Overall, in the name of ‘cishan’, the state delineates a state-sanctioned scope for NGOs and provides directional guidance for their engagement. NGOs are thereby channelled into a depoliticised field, reducing their role to that of nonconfrontational service providers. Whereas the civil society discourse implies that NGOs may challenge the state, the charity discourse reinforces existing power asymmetries by positioning NGOs as subordinate followers of the state’s policy agenda.

Erasing the Civil Society Discourse

While promoting a charity-oriented discourse, the state has not stopped eliminating the influence of civil society discourse—a necessary step in establishing discursive hegemony. Coercive capabilities have long served as an effective instrument for keeping the NGO sector under scrutiny, and this period has been no exception. Since 2012 power, numerous outspoken NGOs and activists focusing on human rights issues have faced repression and been forced to change their roles, if not withdraw from the NGO field. Along with their retreat, the rights-based civil society discourse they espoused has been heavily censored and has ultimately receded.

During Xi’s first term, the state launched multiple crackdowns targeting well-known NGOs and activists. Many individuals were detained and the organisations to which they belonged were forcibly shut (Zhu and Lu 2022). Repression of civil society during this period was campaign style and focused on prominent actors within the field. For grassroots NGOs, which are highly sensitive to shifting political signals, the message conveyed by these crackdowns could not be clearer.

Not only has NGOs’ engagement in rights-defence activities been subject to harsh repression, but also the state has stringently restricted the language they use to articulate their claims. These changes were visible during my fieldwork from September 2021 to May 2022 in the Pearl River Delta (PRD) region of Guangdong, where I interviewed 37 practitioners from 30 grassroots NGOs. I found that labour NGOs had experienced major setbacks. The PRD is a region where workplace injuries occur frequently and many NGOs previously assisted injured workers with legal consultation. However, during my fieldwork, such organisations had largely disappeared due to government pressure. The remaining NGOs serving workers adjusted their framing, emphasising that they served ‘migrant populations’ (流动人口)—a less politically sensitive term. Their activities shifted towards service provision, such as organising hobby groups and informal gatherings and offering low-cost early childhood education.

A similar pattern occurred among LGBTQIA+ NGOs. As terms such as tongzhi (同志, ‘comrade’, a term used in Chinese-speaking contexts to refer to LGBTQIA+ communities) and tongxinglian (同性恋, ‘homosexual’) were heavily censored, these NGOs were compelled to remove such language from their organisational names and publicity materials, effectively becoming LGBTQIA+ NGOs that could no longer explicitly reference LGBTQIA+ identities. One LGBTQIA+ NGO I encountered had originally aimed to function as a pressure group supporting LGBTQIA+ rights. As the political climate shifted, however, it first changed its name and then repeatedly adjusted its activities to continue its work. Despite these efforts, the organisation was ultimately forced to shut under mounting political pressure. For both labour and queer-focused NGOs, organisational survival required progressively shedding the rights-based language that had previously been integral to their identities.

As the state introduced an expanding body of laws and regulations bringing various aspects of NGO operations under tighter control, its use of coercive power has become increasingly subtle and calibrated. The state no longer needs to rely on high-profile crackdowns to shut disfavoured organisations. Instead, within the existing institutional framework, authorities can invoke regulatory and procedural justifications to place NGOs in a difficult position, constraining their operations.

Bringing NGOs’ fundraising channels under scrutiny has proven effective.

Overseas funding is an important source of financial support for grassroots NGOs. In 2017, the state promulgated the Law on Administration of Activities of Overseas Nongovernmental Organisations in the Mainland of China, introducing a pre-screening process that allows authorities to determine whether domestic NGOs may receive funding from overseas donors. Without prior approval, grassroots NGOs that receive overseas funds face penalties. For organisations heavily reliant on foreign funding, this measure represents a major setback. An activist from a rights-advocacy NGO told me that his organisation ceased operations after its funds were exhausted, as he had anticipated that its funding sources would be unlikely to receive approval.

This pre-screening mechanism grants the state substantial discretion, placing it in a dominant position vis-a-vis NGOs. In 2020, one local government unexpectedly rejected a funding proposal from an overseas NGO. The project had operated for years and benefited multiple grassroots NGOs in the PRD. The sudden suspension of funding immediately pushed these organisations into financial distress.

Even domestic funding sources such as online crowdfunding to which NGOs turned as a replacement have proven vulnerable to state control. The Charity Law stipulates that NGOs qualified to raise funds from the public may launch online crowdfunding projects on state-approved platforms. Only a small portion of NGOs in China—most of them foundations—possess this qualification. Grassroots NGOs therefore collaborate with qualified foundations to initiate crowdfunding campaigns. However, all online content is subject to state censorship. NGOs working on sensitive issues must remove politically sensitive language from project descriptions. For some NGOs under scrutiny by public security authorities, pressure is even exerted on partner foundations, demanding that they terminate collaboration.

Campaign-style governance has not disappeared. From 2018 to 2023, the Chinese Government launched three cross-departmental, nationwide special campaigns to ‘combat and rectify illegal social organisations’. Organisations that were not registered with civil affairs authorities but self-identified as NGOs were among the primary targets. More than 14,000 ‘illegal’ NGOs were penalised during the first campaign in 2018 (Yang 2021). With the promulgation of the Measures for Banning Illegal Social Organisations in 2025, the campaign to ‘combat and rectify illegal social organisations’ has, in recent years, become routinised and an important task for civil affairs authorities. In the past, due to factors such as high registration thresholds and the avoidance of state supervision, many grassroots NGOs operated without formal registration. This was previously tolerated by the state but today serves as an invitation for state repression.

Whither Chinese NGOs?

The burgeoning of Chinese NGOs was shaped in the context of the ‘associational revolution’ that swept across the globe (Salamon 1994). The collapse of communist regimes in the late 1980s led some scholars to optimistically believe that bottom-up voluntary associations could evolve into social forces capable of balancing state power and thereby accelerating the breakdown of authoritarian rule. By 2026, however, authoritarian regimes have demonstrated their capacity to manage challenges arising from civil society. Recent studies have identified policy diffusion among authoritarian states in their efforts to tame vibrant, rights-claiming NGO sectors (Carothers and Brechenmacher 2014; Glasius et al. 2020; Roggeband and Krizsán 2021). I further this discussion by focusing on the contestation over discursive space between the state and grassroots NGOs, which has often been neglected in previous scholarship.

Supported by empirical evidence, my argument resonates, to some extent, with Snape and Wang’s (2023) ‘command civil society’ framework, which emphasises the Chinese Communist Party’s efforts to expunge ‘civil society’ discourse and instead promote its preferred discourse centred on ‘charity’, with the aim of consolidating its dominance in NGO governance. However, unlike their particular emphasis on the role of the party in shaping institutions that penetrate civil society, my fieldwork suggests that the party’s presence at the grassroots level remained somewhat limited. Party-building and party work were largely absent in some grassroots NGOs I interviewed and local executive branches were the primary state actors with which they interacted. Therefore, my analysis treats the Party-State as a unified entity and sheds light on its attempts to reassert control over agenda-setting and to compel the NGO sector to transition into one that primarily serves the state’s broader policy initiatives.

In their interactions with the state, Chinese grassroots NGOs and their civil society partners have consistently been the weaker parties. What they have possessed, however, is a discursive advantage, which they have at times leveraged to gain societal support and prompt a government response (Steinhardt and Wu 2016). Framing their claims in terms of rights protection, they have often been able to derive moral legitimacy and, in some cases, shape the policy agenda. As a result, despite the state’s superior material and institutional power, authorities have often been prompted to respond to demands raised by NGOs.

In the Xi era, the Party-State has demonstrated its capacity to alter this dynamic. Backed by coercive power, the state has effectively transformed the institutional landscape of NGO governance. NGOs deemed politically undesirable have become more vulnerable to state repression, while narratives shaped by civil society discourse have been largely suppressed. Meanwhile, in the discursive sphere, with the introduction of the Charity Law and a series of related regulations in the philanthropic sector, the state has constructed a ‘charity-centred’ framework that encourages NGOs to engage in philanthropic activities and assist in providing services to populations in need.

For the remaining NGOs, the most viable strategy for avoiding unwanted state intervention is to embrace this ‘charity-centred’ discourse by rebranding themselves as organisations that align their goals with state policy priorities, depoliticise their activities, and focus on service provision. Even when encountering rights-related issues, they address them by invoking state legislation and policies, operating through state-approved channels, and refraining from disruptive forms of action. The state is thus no longer viewed as a contestable entity but rather as the ultimate arbiter of their organisational legitimacy. In this sense, the Party-State has developed a ‘charity-centred’ discourse as a form of discursive hegemony in the public sphere, thereby further consolidating China’s authoritarian rule.

Not all grassroots NGOs have managed to adapt to the new institutional landscape. As discussed above, despite making repeated compromises, some NGOs that previously engaged in rights-advocacy campaigns and maintained a critical stance towards state power have ultimately ceased operations under sustained state pressure. Some NGOs serving migrant populations have attempted to continue empowerment-oriented work while avoiding rights-based issues. However, some of their efforts—such as cultivating self-motivated community volunteers—face inherent limitations that are difficult to overcome and are therefore hard to sustain.

For grassroots NGOs, which are typically small and have limited social networks, the contraction of operational space has also translated into increasing fundraising difficulties. Their marginalisation appears difficult to reverse. A relaxation of state control may be the only way to alleviate this situation; however, no-one can predict when the next round of political liberalisation will occur. Under such challenging conditions, for NGO practitioners, persisting with their work is itself an admirable achievement.

Featured Image: Wither. Source: @sringsmuth, Flickr.com (CC).

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