Ignorance and confusion abound when it comes to China’s religious laws. Accurate takes are hard to come by. For instance, the The Washington Stand wrote on April 10 in response to China’s “new” rules governing the religious activities of foreigners, set to go into effect on May 1:
“China’s communist dictator Xi Jinping has tightened his grip on religious activity in the world’s second most populous country, as the Chinese Communist Party (CCP) announced last week that starting May 1, foreign missionaries will be prohibited from sharing their faith or preaching, as well as establishing religious organizations.”
It sounds ominous enough. Get ready. Dictator Xi is tightening his grip. On May 1, foreign missionaries will be prohibited from preaching or establishing religious organizations. But the simple fact is that these activities have already been officially verboten ever since the Communist Party of China gained full control of the Middle Kingdom in the mid-20th century.
International Christian Concern states the case a little bit more accurately:
“Chinese state media claimed that the newly revised rules promote national security — a common justification for CCP persecution of religion — and help to protect ‘normal religious activities,’ referring to activities run under strict government oversight as part of state-run religious institutions.”
“Newly revised” is the key phrase here, and is much more accurate. Here’s an English translation of what is officially titled the “Rules for the Implementation of the Provisions of the People’s Republic of China on the Administration of Religious Activities of Foreigners in the Territory of the People’s Republic of China” (access the Chinese original here), which are by and large just a rehashing of laws that have long been on the books, as anyone who has been involved in underground missionary work in China knows well.
I pulled up an older version, published in the year 2000, of the “Rules for Religious Activities of Foreigners” (my abbreviation), which contains a list of twenty-two regulations. The newly revised list of laws has been expanded to thirty-eight, but there is a ton of overlap in the two documents.
The newer regulations seem to have primarily added more red tape to the already onerous application system for the very few officially permitted religious activities in China. The copious amounts of “legalese”, extra layers of guidelines, and stipulations for all kinds of so-called “legal religious activities”, function as a de-facto deterrent to religious work.
Imagine having to go through multiple “DMV” style layers of bureaucracy just to get an invitation to preach or a sermon pre-approved by your local authorities. Here is a good example taken from Article 6 of the previous version (2000) of the “Rules for Religious Activities of Foreigners”:
2000 (Article 6):
At the invitation of Chinese religious bodies…[foreigners] visiting China as religious personnel may preach and expound the scripture at lawfully registered sites for religious activities. At the invitation of Chinese religious bodies…and after approval by the department of religious affairs of the people's governments at or above the provincial level, [foreigners] entering China as other status may preach and expound the scripture at lawfully registered sites for religious activities.
“At the invitation of.” “Lawfully registered sites.” “After approval by.”
These phrases are repeated multiple times and represent roadblocks put in place to stop anything even potentially controversial (or Biblical) from going public. I was once told by the Chinese police that I needed to first have my tracts approved by the provincial Religious Affairs Bureau before I could use them. But the offer was not made in good faith. Any request would have been summarily dismissed. The bureaucracy functioned as a locked door.
Now that paragraph (from 2000) is nearly identical to the parallel paragraph in the 2025 version of the same laws. However, I want to share a new paragraph that has been added in the latest version, which gives even more conditions to the “permission” being granted:
2025 (Article 21):
The invitees shall meet the following conditions:
(1) they shall abide by China’s laws, rules and regulations, respect the principle of the independence and autonomy of China’s religions, and have no words or deeds hostile to China, or extremist ideological tendencies of religions; (2) the contents of the sermons they intend to give do not violate China’s laws, rules and regulations, interfere with China’s religious affairs, or contravene China’s public order and good morals.
Evidently the previous version of the law was too ambiguous for the paranoid Chinese Communist officials. They grant freedom of expression (within the confines of the officially permitted churches) with one hand, then take it right back with the left. “You can preach, if invited by official churches and if approved by the governmental authorities, but…” But what?
But you must “have no words or deeds hostile to China, or extremist ideological tendencies of religions [and] the contents of the sermons [mustn’t] violate China’s laws, rules and regulations, interfere with China’s religious affairs, or contravene China’s public order and good morals.”
This one example alone, ostensibly dealing with “officially permitted religious activities”, clearly shows that true freedom of religion and expression in modern Communist China has always been a facade and a farce.
But there is also a section of the “Rules for Religious Activities of Foreigners” that includes a list of expressly prohibited religious activities by foreigners. In the 2000 version of the law, it is found in Article 17. In the 2025 version, it is found in Article 29.
Note that everything found in the 2000 version is also found in the 2025 version, but the latest edition has been expanded. It is also more wordy. And there do seem to be a few new additions to the list of “verboten” activities for foreigners in China:
Here is the 2025 list, with three new or updated regulations highlighted in bold:
2025 (Article 29):
Foreigners in China may not engage in the following religious activities:
(1) Interfering with and controlling the affairs of China's religious groups, religious schools, and religious venues, and interfering with the identification and management of religious clergy;
(2) Establishing religious organizations, service agencies, activity sites or schools;
(3) Propagating religious extremist ideas, supporting and financing religious extremism and illegal religious activities, and using religion to undermine China's national unity, ethnic unity, religious harmony, and social stability;
(4) Conducting sermons, lectures, or collective religious activities without authorization;
(5) To develop religious followers among Chinese citizens and appoint religious clergy;
(6) Using religion to carry out activities that hinder the implementation of China's judicial, educational, marriage, social management and other systems;
(7) Producing or selling religious books, religious audio-visual products, religious electronic publications, or other religious supplies, or distributing religious propaganda materials;
(8) Accepting religious donations from Chinese organizations and citizens;
(9) Organizing and carrying out religious education and training;
(10) Using the Internet to conduct illegal religious activities;
(11) Other illegal activities involving religion.
Most of these rules or prohibitions are fairly straightforward and self-explanatory. You are not allowed to start schools or religious NGOs (2), you can’t preach or teach without permission (4), you can’t make disciples or ordain ministers (ie, plant indigenous churches)(5), and you can’t produce or distribute Christian media of any kind (7).
I was personally arrested, interrogated, and deported in 2018 for breaking the seventh rule, for distributing “unapproved” tracts and Bibles. I have also been stopped at Chinese Customs and Immigration numerous times for bringing in “too many” Bibles or tracts. In those cases, they will generally confiscate the majority, usually leaving you with a token handful. Then they issue an official letter that permits you to pick up the illegal media on your way back out of the country.
Continuing on, you are forbidden to receive offerings for religious purposes from within China (8), you can’t carry out informal teaching and training sessions (9), which has been a very common and effective way for American pastors to disciple and mobilize Chinese ministers in the past few decades. Note, you can’t do any of the aforementioned things on the internet either (10). And finally, if we missed anything, we’ll make something up when the time comes (11).
That was a quick overview of most of these direct prohibitions. However, in the spirit of expository preaching, let me take the three highlighted points above as if they were verses needing more explanation. Here are a few comments to go with the first, third, and sixth regulations. There is a lot just under the surface here that the average eye might not notice.
The first regulation is specifically aimed at large, powerful, foreign churches, denominations, or organizations (ie, the Vatican), who seek to maintain some sort of direct control over their religious adherents within China’s borders. Note that “interfering with the identification” of religious clergy is a shot at previous Roman Catholic attempts to choose their own Chinese bishops. It also no doubt preemptively forbids the Central Tibet Administration’s future attempt (from India) to choose a new Dalai Lama for all Tibetans (including those within China), when the current Dalai Lama passes away. This is a fight that is coming one way or another, with both China and the Tibetan Government in Exile vowing to “identify” the future Dalai Lama.
The third regulation above is primarily targeting issues related to Muslim extremism, which China has dealt with to varied degrees for decades in its far western reaches. Some extremist Uyghurs have also committed (or attempted) terrorist acts in various places in central China.
Christians can also run afoul of this law by actively seeking to convert and plant churches among Buddhist or Muslim ethnic groups, thus (in China’s eyes) putting “ethnic unity” and “religious harmony” at risk unnecessarily.
The sixth regulation contains subtle hints aimed at those who would promote (among other things) Christian nationalism, Christian education (including homeschooling), or criticize other social policies in China such as abortion.
The comment about marriage would mostly be aimed at certain cults who promote polygamy or other deviations from normal marriage. Other than having a rising divorce rate (although still not as high as America’s), China does not legally permit other obvious perversions of marriage.
The Washington Stand reports that the “latest crackdown on independent religious groups is part of a larger pattern of religious persecution under Xi’s regime.”
The Christian Daily writes that “the new legislation reflects China’s ongoing campaign under President Xi Jinping to assert tighter control over religious practices within its borders. Xi first articulated a goal to ‘Sinicize’ all religions in 2016, a policy designed to ensure religious loyalty aligns with the priorities of the Communist Party.”
The Christian Daily continues: “The independent house church movement has particularly felt the effects of this policy shift. Raids and arrests targeting house church members have become commonplace, as Chinese authorities seek to dismantle groups deemed to pose threats to ‘political security and social stability.’”
These things are all true. The rules have tightened under Xi. Persecution is more prevalent now than it was in the early 2000s. Most missionaries have been forced out of the country since 2018. However, some are taking these warnings way too far.
In The Washington Stand article, Arielle Del Turco, director of the Center for Religious Liberty at Family Research Council, “expressed grave concern over the new restrictions”:
“The Chinese government is openly announcing it is cracking down even further on missionaries trying to serve the Chinese people. Now new regulations will officially ban foreigners from preaching or even just sharing their faith. This will make it much more dangerous for Christians — especially those in ministry — who seek to travel to China.”
This is just simply untrue. The “new laws” contain clarifications and a few minor additions, but nothing substantially different. It has rarely, if ever, been truly “dangerous” for missionaries serving in China, and it is not “more dangerous” now for Christians who seek to live and share the Gospel in China.
Del Turco continued: “The U.S. government should take particular note of this development [as] it will likely affect U.S. citizens who might simply share their faith on a short visit to China.”
This comment angers me. I can say with total confidence that no American (or any nationality for that matter) will be affected by these rules for simply “sharing their faith on a short visit to China.” None. Zero. Zilch. Ling (“Zero” in Mandarin).
There are indeed parts of these regulations to be aware of, and some that will likely get you detained (and probably deported, as I was). But there is nothing to be afraid of for a tourist, student, teacher, or businessman casually sharing their faith with someone they meet in China..
So what are the potential consequences for ignoring or breaking China’s religious laws?
Let’s look at a couple of the relevant articles from the latest regulations:
2025 (Article 34):
Anyone who provides conditions for illegal religious activities by foreigners in the country shall be dealt with in accordance with Article 71 of the Regulations on Religious Affairs.
This warning is aimed not at the religious foreigner, but at a Chinese person, business, or organization who “provides” a location or otherwise helps to facilitate illegal religious activities by foreigners. Article 71 states that in such a case “the religious affairs departments are to give a warning and confiscate the unlawful gains or illegal assets, if any; where the circumstances are serious, a fine of between 20,000 and 200,000 yuan is to be imposed.”
China often uses the threat of this punishment to make it difficult for foreigners or locals to find locations to hold meetings, or have any kind of a ministry presence. If you rent to an offender, you can be prosecuted as stipulated above. The local police warned our landlords numerous times over the years not to continue renting to us because we were under suspicion of being involved in illegal religious activities. They never actually prosecuted anyone, but used the threat to force us to move out of their jurisdiction.
But what about foreign religious offenders? What potential punishment do they face?
2025 (Article 35):
Any violation of other provisions of these Implementation Rules shall be handled by the religious affairs department and other relevant departments in accordance with the "Regulations on the Administration of Religious Activities of Foreigners in the Territory of the People's Republic of China" and the "Regulations on Religious Affairs".
Any violation of the provisions of these implementation rules and at the same time any violation of other laws and regulations shall be dealt with by the relevant departments in accordance with the law; if a crime is constituted, criminal liability shall be pursued in accordance with the law.
That is a long way of saying that the rules are complicated and we will do whatever seems fit.
But in all seriousness, the closest relevant law that I could find is found in Article 70 of the “Regulations on Religious Affairs”:
Where there is proselytization, organizing of religious activities, establishment of religious organizations, or establishment of religious activity sites in schools or educational institutions other than religious schools; the organ of review and approval or other relevant departments are to order corrections to be made within a certain time and give warnings; where there are unlawful gains, they are to be confiscated; where there circumstances are serious, order that enrollment is to be stopped and cancel education permits; and where a crime is constituted, criminal responsibility is pursued in accordance with law.
Let me break this down by using an actual example. Let’s say that a foreign teacher is turned in by someone for inviting students to an informal Bible study in their university-provided apartment every Saturday. The teacher is clearly guilty of “proselytization, organizing of religious activities” and the “establishment of religious activity sites in schools or educational institutions other than religious schools”.
First, the “organ of review and approval or other relevant departments are to order corrections to be made within a certain time and give warnings”.
In practice, this means that the teacher will be officially reprimanded by the appropriate school authorities for being involved in activities not approved under their teaching contract.
Second, “where there are unlawful gains, they are to be confiscated”.
If any offerings or finances were provided to the teacher by a student, they would be confiscated or returned. However, this is unlikely to have taken place in the example given.
Third, “where there circumstances are serious, order that enrollment is to be stopped and cancel education permits”.
Who defines the seriousness of the circumstances? In our current example, serious might mean an ongoing (years?) Bible study that has influenced dozens or hundreds of students on campus. In this case, the teacher would most likely be terminated (fired, not killed) and their work permit cancelled. This would serve as a de facto deportation, and they would have to leave China within a few days or weeks (at the most).
Fourth, “where a crime is constituted, criminal responsibility is pursued in accordance with law.”
The primary purpose of this summary statement is to instill trepidation. Don’t even think about doing anything illegal. You could be prosecuted to the maximum extent of the law. It leaves the door open for wide interpretation and application, depending on the local circumstances. If it is hard to prove that a religious law has been broken, then any old law will do. For instance, authorities in some cases have convicted church deacons of “embezzlement” or other financial crimes, for being involved in collecting and counting church tithes and offerings.
However, it is extremely rare for a foreigner to be prosecuted criminally for missionary work. The police just do not typically treat the “religious crimes” of foreigners that seriously. Instead, warnings are given or immigration rules are enforced by cancelling visas or work permits. The process feels much more like getting a ticket for a misdemeanor. I was detained, interrogated, and deported, but I was never searched or handcuffed. I was never treated like a “real” criminal, unlike faithful pastors such as Wang Yi.
China is emphatically not lying in wait to arrest foreign missionaries. However, they would love for all visitors to keep their mouths shut (out of fear) about Jesus when they come, to leave their Bibles at home, and to refrain from doing anything that might risk breaking China’s religious law.
So China hawks often play into the hands (and plans) of the Communist Chinese by making things seem more dangerous or risky than they really are. If, with the help of certain Christian media, the “newly revised” laws keep thousands of potential missionary teachers or Christian tourists away from the Chinese people, then they will have served their purpose as pawns of China's vast propaganda and influence machine.
We dishonor the testimonies of countless thousands of Chinese Christians who have been arrested, beaten, tortured, and martyred, or who are currently serving prison sentences, by allowing the Chinese administrative state to scare us away with the (unlikely) threat of merely being reprimanded, fined, or deported.
We risk falling into the category of coward that John Piper once described sarcastically:
“Let them shed their blood, not us. We’ll just give them money. We’re nice, comfortable, secure Americans. We’ll just send our money and then go to Disney World. We’re not going to put our necks on the line…”
So, if circumstances and budget permit, go visit China and share Christ with everyone you meet!
And if you cannot go yourself, then give to help send someone else to serve in China.
And last, but definitely not least, please pray for China!
