Myanmar’s 2022 Registration Law

Preliminary Impact Assessment


On 28 October 2022, the State Administration Council (“SAC”) enacted the Organization Registration Law (“ORL”), replacing the former Association Registration Law 2014 (“ARL”). The new Registration Law is draconian and threatens Myanmar’s already highly restricted, post-coup civic space and. In addition to invasive surveillance and oversight, the ORL removes the voluntary provision of Myanmar’s 2014 ARL, and mandates registration for all associations regardless of size or location, under penalty of criminal sanctions.

The new Registration Law came on the heels of Myanmar’s blacklisting by the Financial Action Task Force one week earlier – a move related to Myanmar’s failure to meet international financial standards related to money laundering and terrorist financing, but that nonetheless had significant impact on domestic civil society due to its effects on financial transfers and its likely trigger of the new association registration legislation by the de facto authorities.

Given the significant implications of the new Registration Law and the FATF blacklisting, the International Center for Not-for-Profit Law (ICNL) commissioned two assessments from local partners to document the impacts of these developments on local civil society. Assessments were conducted from January to March 2023, involving interviews and field research with a wide network of Myanmar civil society. The assessment reports document major changes in the policy landscape of associations’ registration and access to financial resources in Myanmar. The main results of the Registration Law assessment can be accessed here, and the FATF blacklisting assessment here.