New administrative measures on religious staff, released by China’s State Administration for Religious Affairs in February 2021, will come into effect on 1 May amid concerns from some religious leaders about their restrictive nature.

One human rights lawyer described the measures as “one more weapon in [the Chinese authorities’] arsenal to limit or further persecute the religious communities.”

The new regulations include specific requirements on the qualifications of religious staff, detailed in the regulations’ Chapter III. Article 15 states that Tibetan Buddhism’s succession of living Buddhas should be regulated in accordance with the Regulations on Religious Affairs and the Tibetan Buddhism Reincarnation Management Measures, which require government approval. Article 16 states that Catholic bishops must be approved and ordained by the state-sanctioned Chinese Catholic Bishops’ Conference.

The Union of Catholic Asian News claims that the regulations “indirectly assert that the election of Catholic bishops will be done by the state-approved system under the Chinese Communist Party’s direction and the Vatican and Pope Francis will have no role in it […] It runs contrary to the laborious China-Vatican deal on appointment of Catholic bishops, signed in September 2018.”

Under Article 27, senior leaders will remain in their position for a term of three to five years. After this, the individual must again submit their personal information to the authorities. In practice, this could be a problem for religious traditions where leaders are appointed for an indefinite period or for life; in addition, religious leaders will be aware that if they criticise or fail to obey regulations, the authorities may refuse their application to re-register (Article 25).  

More broadly, the regulations include requirements that clergy “support the leadership of the Communist Party” (Article 3), which likely translates into a prohibition on any criticism of Party actions and policies. The regulations also stipulate that clergy must not “endanger national security” or be “dominated by foreign forces” (Article 12). These terms are consistent with other regulations on religion, including the revised Regulations on Religious Affairs.

In response to the regulations, one pastor drew parallels to a practice implemented in the 1990s in which the authorities promoted the ‘Preachers’ Certificate’ whereby only religious personnel who had the certificate were considered as ‘lawful’ personnel, but “in practice, it didn’t work.” The pastor added, “We need time to find out the impact of these regulations.”

Other church leaders say that the regulations are part of a wider pattern of restrictions, and in fact the real situation of religious leaders is often much more restrictive than the regulations. Another pastor concluded: “Sinicization of religion is in fact the ‘partyisation’ of religion, and in the end there is only the CCP and no religious beliefs.”

Tibetan official Kelsang Gyantsen told Voice of Tibet that in releasing the regulations, the CCP's main purpose is “to ensure that the authorities' policy of Sinicization of Religion is not obstructed by outsiders” and “to make the measures a tool for suppressing religious activities”.

CSW’s Founder President Mervyn Thomas said: “These regulations have concerning implication for freedom of religion or belief in China; however, as with the revised Regulations on Religious Affairs, what is even more significant than the regulations themselves is the context in which they are being introduced. Religious communities across the country are facing increasing pressure to conform to a Party-approved version of religious practice. In some cases, it is subtle; in others, it is an outright assault on communities’ rights and freedoms, as it is in the Uyghur Region. In any case, where churches and other communities have resisted this pressure, their leaders have faced harassment, threats and even prison sentences. We call on the Chinese government to protect the right to freedom of religion or belief for all citizens of China, in line with their universal human rights.”