China’s Charity Law effectually governs a broad universe of non-profits while refusing to define essential terms. And, of course, organizations the government regards as sensitive—including some religious, political, human rights, and other independent associations of particular segments of civil society—will not be permitted to register despite likely compliance with the law. But what does it mean, under the Charity Law, for an activity to be “charitable”? Though the Charity Law for the first time provides comprehensive regulation within the non-profit sector (including regulation of organizational and management requirements, fundraising and donations, volunteer activities, transparency and reporting requirements, and other provisions), it still does not clearly define this term.

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