“Chinese house church leaders and even ordinary Christians there have increasingly become targets of the authorities, and we expect that crackdown to worsen when this new law goes into effect,” says Voice of the Martyrs Korea Representative Dr. Hyun Sook Foley. Her organization has been partnering with underground Chinese churches for years, providing aid to families of church leaders imprisoned for their faith and helping Chinese Christians prepare for persecution. She says that despite the penalties, underground church leaders remain committed to not registering their churches with the government.

“While the unregistered churches face more and more persecution, the registered churches face more and more requirements from the Communist party to praise communism in their sermons and hymns and refrain from providing congregation members access to classic Christian books or discipling the children in the congregation,” says Representative Foley. “House church leaders have seen that registering their churches is just the first step in a process leading to greater government control over what the church can say, do, and believe. So the church leaders would rather go to prison than abandon their church members or deny the historic Christian faith.”

The newly promulgated Measures replace the Interim Measures for the Suppression of Illegal Non-governmental Organizations issued by the Ministry of Civil Affairs in April 2000.

Among the changes in the new regulations are expanded powers for police investigating suspected illegal organizations. Article 10 says that when investigating cases, authorities may enter the venue of the suspected organization to conduct on-site inspections, access and copy contracts, documents, account books, meeting minutes, and promotional materials.

The new regulations also make it possible for police to make audio or video recordings, take photographs, and retain electronic data as needed.

“We’ve seen authorities increasingly cracking down on church members trying to use cell phones to record when police raid their worship services,” says Representative Foley. “Now these new laws formalize the right of police to do all forms of recording and photography during their raids, which can then be used in their investigations and prosecution of house church leaders.”

The measures also emphasize that all individuals have the right to report illegal social organizations to authorities. In order to facilitate citizen reporting, the measures require that all government agencies that investigate illegal organizations must publicize their contact information and instructions to enable citizens to easily make such reports.

“Reporting information to the government about suspected illegal organizations is portrayed as a citizen’s ‘right’, rather than just a requirement, in the new measures” says Representative Foley. “The measures promote the idea that illegal organizations like house churches threaten ordinary people by their very existence, so the government should make it easier for citizens to fight back against them. But Chinese law states, ‘Everyone shall have the right to freedom of association with others’. So it is not house churches that threaten ordinary people. It is laws like these new measures against so-called illegal organizations that threaten ordinary people by further restricting their rights.”

Representative Foley says that in the original “Interim Measures”, authorities had only one way to deal with illegal social organizations: ban them. But the new measures offer authorities a range of possible punishments. “Instead of or in addition to banning, authorities will be able to issue administrative penalties and public security penalties, as well as criminal liability. So a pastor of a house church could face a heavy fine and a prison sentence simply for pastoring an unregistered church, even though everything about the church is operating correctly. The mere existence of an unregistered church becomes a crime.”

Representative Foley says she spoke by phone last week with a church leader in China who was released from prison last year. “The church leader told me that he is aware of more than 100 other church leaders who are presently in prison in China. Some have been detained for more than two years without a trial date even being set. When the new regulations go into effect, we would expect those numbers to increase.”

Individuals interested in learning more about the persecution of house church Christians of China can visit https://vomkorea.com/en/project/china.