The Mongolian Evangelical Alliance (MEA) reported it obtained without difficulty permission to organize an October demonstration in the city’s central square from the Ulaanbaatar city authorities. A Shamanist leader, however, reported that a local provincial authority in Zavkhan Province prevented members of his organization from participating in a ritual celebration.
Registration and renewal procedures for religious institutions reportedly varied significantly across the country, largely depending upon the practices of local government officials. Some religious groups continued to say the government inconsistently applied and interpreted regulations, changing procedures frequently and without notice. Some religious groups continued to state that the registration and renewal process was arbitrary in some instances, with no appeal mechanism for denials. A Christian group reported that an Uvs Province local assembly chairperson stated he was biased against the group.
The length of the registration process reportedly varied from several weeks to years, deterring some Christian religious groups that wished to register. Some groups reportedly did not try to register because they were unable to fulfill the legal requirements for registration due to insufficient size or lack of dedicated, regular worship sites.
Ulaanbaatar Assembly officials continued to say the registration and renewal process allowed the government to assess the activities of religious groups, monitor the number of places of worship and clergy, and know the ratio of foreigners to nationals conducting religious activities. After a religious organization filed for new registration or renewal, according to Ulaanbaatar Assembly officials, a specialized team visited the applying organization to conduct an inspection to determine whether it met specific registration requirements for religious legal entities. This inspection team was composed of individuals from relevant agencies, such as the National Police Agency, General Intelligence Agency, and General Agency for Specialized Inspection. The officials continued to say any applications for initial registration or renewal that ostensibly were “denied” were more accurately “postponed” because of incomplete documentation, poor physical conditions of the place of worship, instances of providing English language instruction in schools without an educational permit, or financial issues (e.g., failure to pay property tax or to declare financing from foreign sources). The authorities said in these cases, they instructed religious institutions to correct deficiencies and resubmit their applications. According to Ulaanbaatar Assembly officials, there were 848 religious organizations in operation nationwide, of which 380 were located in Ulaanbaatar. The officials stated that of these, 300 were officially registered and 80 were operating without valid registration.
The Ulaanbaatar Assembly limited registrations and renewals to one year from the date of issuance, although local authorities in some other areas granted registrations and renewals that were valid for two or three years. As of October, the Ulaanbaatar Assembly granted renewals for 70 religious organizations, cancelled five registrations, and suspended 23 registrations pending additional documentation, improved conditions, or other issues as determined by the inspection team. An Ulaanbaatar Assembly official said Christian groups constituted the majority of those seeking registrations or renewals; for this reason, most of the cancelled or suspended registrations were for Christian groups.
The Ulaanbaatar Assembly and other local assemblies continued to decline to recognize branch churches as affiliated with a single religious institution; instead, each individual church was required to register separately. According to Mormon leaders, the Ulaanbaatar Assembly’s position that branches of the same church required separate registrations, which had unclear status in the law, continued to cause particular problems for Christian denominations seeking to operate multiple churches under a centralized administration, although such denominations were able to register their churches individually.
Unregistered religious groups were often still able to function, although at times they experienced frequent visits by local tax officers, police, and representatives from other agencies. Some religious leaders expressed concern that unregistered status could leave their organizations vulnerable to investigation and possible legal action. Shamanist leaders expressed concerns that the requirement for a registered place of worship placed limitations on their religion because of its nature-linked practices, although a few established registered places of worship. Two Christian denominations also reported this requirement restricted their ability to hold worship services in members’ households. Unregistered churches lacked official documents establishing themselves as legal entities and as a result were unable to own or lease land, file tax returns, or formally interact with the government. Individual members of unregistered churches typically continued to own or lease property for church use in their personal capacity.
Religious leaders continued to report that religious organizations in Tuv Province experienced registration difficulties. These leaders also noted that unregistered religious organizations were able to operate.
There were no reports of registration difficulties in Darkhan-Uul Province by religious groups that previously experienced such issues.
The MEA also reported it no longer experienced barriers to registration in Khuvsgul and Dornogobi provinces.
The Administrative Court of First Instance in Ulaanbaatar ruled in favor of a Jehovah’s Witnesses congregation that filed a court petition contesting the Ulaanbaatar Assembly’s decision to cancel its registration based on the assembly’s determination that the church doctrine was potentially harmful to national security. As a result, the church was able to apply for renewal of its registration. The renewal application was pending at year’s end. There were reports that three additional Christian congregations also had their registrations cancelled for the same reason.
During an interfaith roundtable event at the U.S. embassy in September, religious leaders unanimously stated that inconsistent implementation of registration requirements posed the only barrier to the free exercise of religious practices.
In many areas, local authorities reportedly continued to place restrictions on the participation of minors in church activities. According to representatives of multiple Christian groups, government officials continued to restrict unaccompanied minors’ participation in religious services due to fears services would be used to “brainwash” them. In Uvs and many other provinces, minors under the age of 16 required written parental permission to participate in church activities. Churches are required to retain this permission in church records and make it available upon request.
Religious groups, as allowed by law, continued to experience periodic audits, usually by officers from tax, immigration, local government, intelligence, and other agencies. Buddhist, Christian, Shamanist, and Muslim religious leaders during an interfaith roundtable said that secular business entities are also subject to similar inspections and experience periodic audits. Some religious leaders in the past said such periodic audits were a form of harassment.
Government officials receive Buddhist leaders annually during the Lunar New Year.
Some foreign citizens continued to face difficulties obtaining religious visas. Since most religious groups were bound by the 95 percent local hire requirement, groups that could not afford to hire enough local employees could not sponsor additional religious visas. It was possible to pay a fee to exceed the quota restrictions, but some churches reported they could not afford this cost. Christian groups reported foreign missionaries seeking to enter the country often did nonreligious work and applied for the corresponding type of visa (such as student or business). As a result, the groups reported they could legally participate only in limited religious activities and were vulnerable to deportation because of inconsistent interpretations of the activities in which they could legally engage. The validity of religious visas is linked to the religious organization’s registration, which some Christian religious groups reported resulted in additional visa problems. Foreign citizens cannot receive or renew a religious visa unless their religious organization’s registration or renewal was already granted. The length of the religious visa’s validity corresponds with and cannot exceed that of its sponsoring organization.
Some local authorities were reported to have sought out the voluntary services of Christian groups for prison counseling, the construction of wells, and other charitable works.
The government allocated funding of MNT 840 million ($346,000) for the restoration of several Buddhist sites that it said were important religious, historical, and cultural centers. The government did not provide similar subsidies to other religious groups.
The task force established in 2016 by the minister of justice to update statistics on religious institutions and identify issues related to religious activities was disbanded following the completion of its work. No report was issued on its findings.