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)
After three articles on the proposed reform of Macau’s Legal Regime for Associations, a more practical question now arises: what should this reform ultimately bring to Macau’s associative sector?
The reform responds to two fundamental requirements: safeguarding State security, while also bringing greater order, coordination, and responsibility to an associative landscape that has expanded enormously over several decades.
Macau now has more than 12,000 associations. Many remain active and provide important services to the community. Others depended for years almost entirely on one person who handled the paperwork, maintained contacts, and kept the organisation functioning. When those individuals passed away or ceased to be involved, some associations were left without any real continuity.
This is not necessarily a story of abuse. It is also the consequence of decades of rapid associative growth during which the mechanisms for oversight and follow-up did not always evolve at the same pace.
Freedom of association is one of Macau’s strengths. I hope society can understand the purpose of this reform and, while the public consultation is still under way, use the opportunity to raise practical questions, clarify doubts, and help improve the way associations operate.
Clearer requirements, better coordination
Those who establish an association, or agree to serve on its governing bodies, should understand the responsibilities they are assuming and the obligations they will have to meet.
Drafting statutes, defining objectives, identifying those responsible, and understanding basic rules on governance, accounts, funding, and external relations are all part of that responsibility. Establishing an association also means learning how to run it properly.
The assistance of lawyers or other professionals can naturally help, but it cannot replace the responsibility of founders and office-holders themselves.
The issue is not whether there should be requirements, but whether those requirements are necessary, clear, proportionate, and understood from the outset.
The proposed central role of the Identification Services Bureau (DSI) may therefore offer an opportunity to improve procedures. Its role need not be limited to supervision; it can also include information, guidance, and coordination between public bodies.
Macau’s small size may actually be an advantage in achieving more effective administrative coordination.
Demanding, but not exceptional
Comparisons with other jurisdictions can help place Macau’s reform in perspective, provided that differences in population, territory, and administrative structure are taken into account.
In the Chinese mainland, the establishment of social organisations is subject to more demanding conditions, including requirements concerning membership, premises, personnel, lawful sources of funding, and organisational capacity, as well as approval and registration by the competent authorities.
Hong Kong follows a different and more administratively concentrated model. Societies are subject to registration or exemption from registration and must also notify subsequent changes to their name, objects, office-holders, or premises. The law likewise allows the authorities to intervene where national security, public safety, or public order are at stake.
Macau does not need to copy either Hong Kong or the Chinese mainland. It can learn from both while developing an approach suited to its own size, history, and legal framework.
Is Macau asking too much? In several respects, other systems are just as demanding, or more so. What matters is that whatever Macau ultimately requires should be necessary, clear, and proportionate.
A lesson from Macau’s sporting history
Macau’s sporting development offers an example of how associative autonomy and institutional responsibility can coexist.
Legislative Enactment No. 1470 of 5 November 1960 regulated what were then known as gymnastic and sporting activities within a framework of strong administrative intervention. Compared with Hong Kong, the autonomy of Macau’s sporting movement developed relatively late.
After 1974, the situation gradually changed. Sporting associations gained greater autonomy and Macau progressively built up its own international sporting presence.
Decree-Law No. 67/93/M of 20 December repealed the 1960 legislation and established a new framework for sporting activities, while retaining an important principle: participation in sporting competitions representing Macau remained subject to the relevant authorisation.
I know this procedure well. Over many years, I prepared numerous reports and proposals seeking authorisation to participate as an official representative of Macau.
Authorisation and the granting of a subsidy were two separate decisions. Participation could be authorised without the requested subsidy being granted, or with only part of it approved. The absence of a subsidy did not mean that participation had not been authorised. The reverse would not make sense: public resources should not finance participation as an official representative of Macau where that participation had not been authorised as such.
Authorisation came before subsidy. Responsibility for representing Macau came before funding. That principle should be clear.
There were also occasions when political or institutional considerations, or concerns relating to the safety of athletes and delegations, could make participation in a particular event inadvisable.
Today, within the framework of the Macao SAR, the same underlying logic remains relevant. An association may legitimately maintain relations with international organisations and take part in activities overseas. Presenting itself as an official representative of Macao, China, is a different matter.
Freedom of association allows organisations to engage with the world. Official representation carries a different level of responsibility.
Better knowledge, better support
This is precisely where the reform presents an opportunity that should not be missed.
Knowing more about Macau’s associations should not merely help determine which ones need supervision. It can also help the Government understand who deserves support, why, and for what purpose.
Public resources are limited. Knowing which associations are genuinely active, what work they undertake, whom they serve, and what capacity they have to deliver can help ensure that those resources are used more effectively.
This does not mean favouring larger associations. A small cultural, youth, social, recreational, or sporting association may do work of considerable value.
What should matter is genuine activity, continuity, responsible use of resources, and benefit to the community.
An Administration that understands the associative sector better does not necessarily have to supervise it more. It can supervise where necessary, simplify where possible, and provide better support where the work deserves it.
State security as a fundamental principle
All these considerations must be understood within one fundamental principle: safeguarding State security.
In the present international environment, it is understandable that the Macao SAR should seek a clearer picture of who establishes and runs associations, their links with entities outside Macau, and the financial flows they receive from abroad or, where applicable, send outside the SAR.
Such transfers may involve international membership fees, registration fees, cooperation projects, donations, or other entirely legitimate purposes. Precisely for that reason, clear rules on the origin, purpose, and destination of funds protect both the public interest and the associations themselves.
Knowing more does not mean suspecting more. It can also help build trust.
What matters is having sufficient information to distinguish normal and legitimate activity from circumstances that, by their nature, may require a different degree of attention.
Security as the priority, coordination as the method, and a stronger associative sector as the result.
After the consultation
The public consultation is still under way. This is precisely the time for these questions to be raised.
Expressing an opinion does not mean opposing the reform. A public consultation exists to clarify doubts, identify practical problems, and improve what can still be improved.
Once the views received have been considered, it would be desirable for the Government to finalise the new framework in due course, without prolonging uncertainty unnecessarily. Associations need to know the new rules, the transitional arrangements, and the procedures for regularisation.
I am not particularly comfortable with the word “clean-up” to describe what may follow. I would rather speak of a serious updating of Macau’s associative landscape. It is somewhat like updating the contacts list on a phone: identifying which associations are still genuinely active, which need to regularise or update their position, and which have in fact ceased operating.
After decades of rapid associative growth, Macau may need less additional control and more effective coordination.
The priority is clear: safeguarding State security.
But there is also an opportunity that should not be missed: using public resources more intelligently and providing better support to associations that genuinely work for and serve Macau.
Perhaps that is the balance to seek: security where indispensable, rigour where necessary, simplicity where possible, and support where it is deserved.
The purpose of the reform should not simply be to reduce the number of associations, but to help Macau develop a stronger, more responsible, and healthier associative sector.
Macao SAR, August 31, 2026
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