Commentary by Manuel Silvério
Independent Analyst on Public Policy and Regional Development
(Former public-sector official with international experience and a long-standing involvement in public policy and sports development)
In recent days, several association leaders have asked me what I think about the proposed reform of Macau’s Legal Regime for Associations, now under public consultation by the Macao Special Administrative Region (MSAR) Government.
Their questions were not simply a matter of curiosity. I sensed genuine concern, particularly among people who have devoted years of their time to associations, often on a voluntary basis, and who now want to understand what may change and what new responsibilities they may be expected to assume.
I understand those concerns, perhaps also because I witnessed a very different period in the development of Macau’s associative movement.
Following the political and administrative changes set in motion by Portugal’s Carnation Revolution in 1974, sport in Macau gradually acquired greater organisational autonomy. I lived through a period when it became necessary to establish territorial sports associations representing the different disciplines, both to organise local sporting activity and to enable Macau to participate in its own right in regional, Asian, and international organisations and competitions.
Those associations were not created simply to increase their number or add names to a register. They were created because they were needed.
Macao subsequently changed, and its associative movement changed with it.
Activities multiplied, participation and competitions increased, and exchanges with associations and clubs in neighbouring cities became more frequent. Numerous sporting, recreational, cultural, social, and other associations and clubs emerged.
Many were a natural product of that growing vitality and continue to serve the community today. Others gradually became less active, while some may have ceased operating altogether.
But behind these associations, there have always been people.
Many have served voluntarily as association leaders, organising activities after work, supporting young people, promoting culture and sport, and keeping small organisations alive simply because they believed their work was worthwhile.
That human dimension should not be forgotten when we discuss legal reform.
At the same time, public support for associations increased over the years, while associations also came to play a role in different mechanisms of social and political representation. Macau’s associative landscape consequently became both broader and more complex.
It would be unfair to generalise or question the valuable contribution made by thousands of association leaders. But it would be equally unrealistic to regard every association as having the same origins, size, level of activity, or social purpose.
It is against this background that the figures deserve attention.
Macao had fewer than 2,000 associations before the establishment of the MSAR. Today, there are more than 12,000. According to the consultation document, only around 60 per cent maintain some level of activity, while approximately 40 per cent have long been inactive or never truly began operating.
The document itself uses a particularly telling expression to describe some of them: “dormant associations”.
There are, therefore, objective reasons for reviewing the system.
A necessary reform
I believe the Government’s decision to undertake this reform is both timely and necessary.
Precisely because I recognise that need, I also believe the public consultation should be used not only to discuss the problems the new legislation seeks to address, but also to consider how the proposed solutions will work in practice.
My position is straightforward: I am not against reform; I am in favour of good reform.
The consultation document states that the reform seeks to better safeguard freedom of association and the legitimate rights and interests of associations, while promoting their orderly and sustainable development.
It also seems reasonable to simplify procedures currently spread across different public entities and to centralise responsibilities for the establishment, registration, and supervision of associations under the Identification Services Bureau (DSI).
Less bureaucracy, clearer procedures, and more up-to-date information can benefit both the Public Administration and associations themselves.
A careful reading of the document, however, shows that this goes beyond administrative reorganisation.
The DSI would have broader powers concerning the operation of associations. It could request information, require irregularities to be remedied, and, in circumstances provided for under the new regime, decide on the dissolution of an association.
The important point is to distinguish between different situations.
For certain irregularities – such as failure to elect or appoint new office-holders or failure to hold a general meeting to approve the annual accounts – the proposal provides for a remedial procedure. An association would first be notified and given an opportunity to put matters in order before any eventual dissolution.
Being required to remedy an irregularity does not necessarily mean dissolution.
A good law should be able to distinguish between a mistake that can be corrected and an association that has effectively ceased to function.
12,000 associations, different realities
An association that regularly organises activities for hundreds of people, a small recreational club, a neighbourhood organisation, a professional body, a cultural association, and one that ceased operating 20 years ago may all share the same legal status.
But they do not represent the same reality.
Legislation intended to regulate more than 12,000 associations should, as far as possible, be capable of recognising those differences.
It is understandable to address the situation of associations that survive only on paper. Requiring governing bodies to be kept up to date, statutes to be observed, and greater transparency is equally reasonable.
But modernisation cannot simply mean more supervision.
Genuine modernisation should also be measured by the simplicity of procedures, clarity of rules, proportionality of obligations, and the certainty provided to those trying to comply with them.
I can also see another possible benefit in obtaining a clearer picture of Macau’s associative landscape, although this is not necessarily an objective of the proposal now under consultation.
Knowing more accurately which associations are genuinely active could, in future, help make the allocation of government subsidies and other forms of public support fairer and more objective.
Public resources are not unlimited. Actual activity, continuity of operation, the relevance of projects, the number of people genuinely benefiting from them, and the proper use of previous public support could reasonably help guide decisions on the allocation of public funds.
This should not mean favouring large associations while overlooking smaller ones. A small organisation may perform extraordinarily valuable work for a neighbourhood, a group of young people, a particular sport, or the preservation of a cultural tradition.
The point is simply to understand the reality better in order to make better decisions.
A better-organised associative landscape could therefore serve not only to improve supervision, but also to improve support.
National security
There is another dimension of the reform that should not be overlooked.
Macao is a Special Administrative Region of the People’s Republic of China (PRC), and its reality must be understood within the country’s constitutional framework and against an international environment that is now considerably different from the one in which the current legal framework for associations was conceived.
National security has become an increasingly prominent concern in a world marked by greater geopolitical competition and new forms of interference. It is therefore understandable that this dimension should also be reflected in the reform of Macau’s Legal Regime for Associations.
The proposal provides for the involvement of the Committee for Safeguarding National Security in certain situations relating to the establishment or dissolution of associations.
Safeguarding national security is a fundamental responsibility of the MSAR, and I do not question the need for appropriate mechanisms where national security is genuinely at stake.
Nor do I regard freedom of association and national security as necessarily conflicting principles.
What matters is that the rules should be clear and proportionate, so that association leaders understand their responsibilities while organisations operating legitimately can continue their normal activities.
One political association yet to be identified
The consultation document contains another point that may perhaps be clarified during the public consultation.
The Government refers to the existence of one political association established before Law No. 2/99/M came into force and proposes transitional arrangements allowing it to continue to exist.
The document does not identify the association.
I do not regard this as a central issue in the reform. But since the association’s existence is the reason for a specific arrangement under the proposed regime, it seems natural to ask which association it is.
That, too, is part of the purpose of a public consultation: to clarify doubts, listen to concerns, and help the community better understand legislation that will affect thousands of organisations and many more people.
Reforming in order to strengthen
Macau has changed profoundly, and its associative movement has changed with it. Growth from fewer than 2,000 associations to more than 12,000 naturally justifies a review of the legal framework.
But numbers never tell the whole story.
Behind those figures are organisations with decades of history and deep roots in the community; small clubs that continue to organise activities; groups working with children and young people; cultural and professional associations; institutions serving residents; and others that have long ceased to operate.
Above all, behind the numbers are people.
A good reform should be capable of recognising these different realities: regulating more effectively those associations that genuinely function; giving those with remediable problems a reasonable opportunity to put matters in order; addressing the situation of associations that remain on the register but have effectively ceased operating; and avoiding unnecessary burdens on those seeking to fulfil their obligations.
If a more accurate picture of associations’ actual activities can also contribute, in future, to a fairer and more effective use of public resources, that would be an additional benefit for the whole community.
Associations have played an important role in building Macau’s civil society – in sport, culture, education, youth affairs, social welfare, and many other fields.
Reform should not erase that history. It should help that tradition continue under rules that are clearer, more responsible, and better suited to Macau today.
That is why I believe reform is necessary.
And precisely because it is necessary, it deserves to be discussed carefully.
There is, however, another dimension that deserves a separate reflection.
Many Macau associations have long maintained links with organisations in the Chinese mainland, Hong Kong, and overseas, some through membership of regional and international bodies. The new obligations proposed in this area raise a different set of practical questions: transparency, compliance, external funding, national security, and coordination among public services.
That will be the subject of my next article.
End Item
Macao SAR, August 12, 2026
